PRESS STATEMENT
Country-Level Revenue Estimates – A Comparative Analysis of UN and OECD Subject to Tax Rules for 65 Member States of the G-24 and South Centre
Washington and Geneva, 23 July 2025
The South Centre & Group of Twenty-four today jointly released country-level revenue estimates of the UN & OECD Subject to Tax Rule (STTR) for their 65 combined Member States.
Results show higher revenues from UN STTR, and reinforce benefits of a UN Tax Convention.
Comparison of Tax Revenue Effects of United Nations and OECD Subject to Tax Rule for G-24 and South Centre Member States
By Faith Amaro and Sol Picciotto
The Subject to Tax Rule (STTR) seeks to address the historical imbalance in the allocation of taxing rights under international tax treaties by introducing within existing treaties a new article which makes the restrictions on source taxation conditional on the residence jurisdiction imposing a minimum level of tax on foreign-derived income. This paper presents a methodology for analysing the respective benefits of the STTRs developed by the Organisation of Economic Co-operation and Development (OECD) and the United Nations (UN). Applying this model to publicly available data for 2021, it also provides estimates of the possible revenue impact for the 65 Member States of the South Centre (SC) and the Intergovernmental Group of 24 (G-24). Our analysis indicates that the OECD STTR would have no impact on any OECD country treaty with a SC/G-24 Member State. Applying the prescribed 9% minimum rate to covered payments, only 100 treaties across 28 SC/G-24 Member States would qualify for improvement under the OECD STTR, with an estimated combined revenue gain of USD 55.6 million, 71% of which is concentrated in just five treaties. In contrast, the UN STTR, which does not specify a minimum rate, was modelled using rates of 9%, 10% and 15%. This resulted in estimated revenue gains of USD 212 million, USD 325 million, and USD 1,165 million across 171, 210 and 317 treaties, respectively. Given its complexity and restrictive scope, it seems pointless for any SC/G-24 Member State to join the OECD STTR. Instead, countries should focus on identifying treaties that cause unjustifiable revenue losses and consider revising them – either by adopting the simpler and broader UN STTR or implementing other measures such as active anti-abuse provisions to combat treaty shopping and tax avoidance.
Analysing the Impact of UN and OECD Subject to Tax Rule for G-24 and South Centre Member States
By Suranjali Tandon and Chetan Rao
The Subject to Tax Rule (STTR) is meant to address base erosion and profit shifting in cross –border transactions. The United Nations (UN) and Organisation for Economic Co-operation and Development (OECD)/Group of Twenty (G20) Inclusive Framework have developed models of the STTR that countries may choose to adopt in their treaties. This paper provides a review of these designs of two STTR models and proceeds to estimate the revenue gains for the Intergovernmental Group of Twenty-Four on International Monetary Affairs and Development (G-24) and South Centre Member States that may arise from a STTR that covers different kinds of payments. The OECD STTR is limited to related-party payments and imposes thresholds based on mark-up and materiality, reducing its applicability in practice. In contrast, the UN STTR offers broader coverage, applies to both related and unrelated parties, and does not impose restrictive thresholds, making it more administratively feasible for developing countries. Although the estimated gains from the OECD STTR appear modest due to its narrow scope, the UN STTR shows greater potential. The analysis also highlights data limitations and the need for access to microdata for accurate country-level assessments.
STATEMENT BY DR. CARLOS CORREA, EXECUTIVE DIRECTOR OF THE SOUTH CENTRE, TO THE MINISTERS AND GOVERNORS MEETING OF THE INTERGOVERNMENTAL GROUP OF TWENTY-FOUR (G24)
22 April 2025, Washington, D.C.
The South Centre statement to the G24 Ministerial Meeting highlights the risks of a darkening global economic outlook and need for collective action at UN and FfD4 for addressing systemic issues & reforming the international financial architecture, especially for taxation & sovereign debt.
STATEMENT BY DR. CARLOS CORREA, EXECUTIVE DIRECTOR OF THE SOUTH CENTRE, TO THE MINISTERS AND GOVERNORS MEETING OF THE INTERGOVERNMENTAL GROUP OF TWENTY-FOUR (G-24)
21 October 2024, Washington D.C.
The South Centre participated in the G-24 Annual Meeting of Ministers and Governors in Washington D.C. See our statement:
STATEMENT BY DR. CARLOS CORREA, EXECUTIVE DIRECTOR OF THE SOUTH CENTRE, TO THE MINISTERS AND GOVERNORS MEETING OF THE INTERGOVERNMENTAL GROUP OF TWENTY-FOUR (G-24)
16 April 2024, Washington D.C.
At the G-24 Ministers and Governors meeting, South Centre highlighted the many economic challenges facing developing countries and called for the urgent reform of the international financial architecture.
STATEMENT BY DR. CARLOS CORREA, EXECUTIVE DIRECTOR OF THE SOUTH CENTRE, TO THE MINISTERS AND GOVERNORS MEETING OF THE INTERGOVERNMENTAL GROUP OF TWENTY-FOUR (G-24)
10 October 2023, Marrakesh, Morocco
To address the global polycrisis, developing countries need to come together to demand reforms in the international rules & architecture for debt, development finance, trade & tax to achieve equitable outcomes, fight climate change and meet SDGs.
STATEMENT BY DR. CARLOS CORREA, EXECUTIVE DIRECTOR OF THE SOUTH CENTRE, TO THE MINISTERS AND GOVERNORS MEETING OF THE INTERGOVERNMENTAL GROUP OF TWENTY-FOUR (G-24)
11 April 2023, Washington, D.C.
Solidarity and international cooperation is needed now more than ever to address the multiple challenges that disproportionately affect developing countries. See the South Centre’s statement to the G-24.
STATEMENT BY DR. CARLOS CORREA, EXECUTIVE DIRECTOR OF THE SOUTH CENTRE, TO THE MINISTERS AND GOVERNORS MEETING OF THE INTERGOVERNMENTAL GROUP OF TWENTY-FOUR (G24)
April 2022, Virtual Meeting
The lingering COVID-19 pandemic, monetary tightening and increasing geopolitical tension have slowed down the global economic recovery. Projections for the 2022 global GDP growth have been slashed by about one percentage point by major international institutions. Together with inflation, especially spikes in food and fuel prices, and ongoing supply chain disruptions, uncertainty and fragility are looming over the two-speed world economic recovery. This has dimmed the hope to halt or reverse the trend of the rapidly increasing number of people falling into extreme poverty and suffering from hunger. While the COVID-19 virus continues to mutate, the access to vaccination continues to be a major world concern. Developing countries’ supply and financing constraints for vaccines and critical medical products must be addressed.
In view of the multiple challenges faced by developing countries, the efforts of G24 in helping to coordinate the positions of developing countries on international monetary and development finance issues remain critical. The South Centre will continue to support those efforts.
Assessment of the Two-Pillar Approach to Address the Tax Challenges Arising from the Digitalization of the Economy
An Outline of Positions Favourable to Developing Countries
Report by the South Centre Tax Initiative’s Developing Country Expert Group
Irene Ovonji-Odida, Veronica Grondona, Samuel Victor Makwe
This report is written primarily for developing country negotiators in the Inclusive Framework and accordingly contains a technical assessment of Pillars One and Two. The aim is to discuss the positions and principles which can inform the negotiations in developing countries’ best interests. However, it is also written for a larger audience, particularly diplomats involved in financing for development discussions and international trade rule making, so as to sensitise them to the nuances of the ongoing discussion on the taxation of the digitized economy. In the midst of the COVID-19 pandemic and a devastating economic downturn, it is more important than ever to ensure that developing countries obtain their due taxing rights. This report is an initial contribution in that direction.
Title: G-24 Technical Group Meeting
Date: 27-28 February 2018
Venue: Colombo, Sri Lanka
Organizer: Intergovernmental Group of Twenty Four
