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Romania Consults on Draft Law to Ratify of Multilateral Instrument to Implement Pillar 2 STTR

15 April 2025

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Treaty Development

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Romania-OECD

The Romanian government has launched a public consultation on a draft law for the ratification of the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI). Romania signed the STTR MLI on 19 September 2024, which provides for the implementation of the STTR in bilateral tax treaties. The STTR allows jurisdictions to "tax back" where defined categories of income are subject to nominal tax rates below the STTR minimum rate of 9%, and domestic taxing rights over that income have been ceded under a treaty. It is designed to help developing countries, in...