The OECD's Forum on Tax Administration (FTA) held its annual Plenary meeting in Singapore from 11-13 October 2023, bringing together tax commissioners and delegates from across the globe, including representatives from international organizations, regional tax administration bodies, business and academia.

At the meeting, Commissioners agreed on new areas of collaboration to pave the way for transforming the future of tax administration, namely: 

• An ambitious set of projects to help realize the vision of Tax Administration 3.0, utilizing the new technology tools to increasingly build-in compliance, drive down tax gaps and significantly reduce compliance burdens; 
• To work together to ensure the effective implementation of the global minimum tax under Pillar Two of the Two-Pillar Solution, including exploring how co-operation between tax administrations can be deepened to support compliance, collaboration and certainty in the administration of the global minimum tax rules; and 
• To enhance the effectiveness and reach of global capacity building efforts through closer partnership with other international and regional organizations.

The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (Inclusive Framework) has released the text of a new multilateral convention that updates the international tax framework to co-ordinate a reallocation of taxing rights to market jurisdictions, improve tax certainty, and remove digital service taxes.

The Multilateral Convention to Implement Amount A of Pillar One  (the MLC) reflects the current consensus achieved among members of the Inclusive Framework. Amount A of Pillar One co-ordinates a reallocation of taxing rights to market jurisdictions with respect to a share of the profits of the largest and most profitable multinational enterprises (MNEs) operating in their markets, regardless of their physical presence.
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It also ensures the repeal and prevents the proliferation of digital services taxes and relevant similar measures, secures mechanisms to avoid double taxation, and enhances stability and certainty in the international tax system.

The Supreme Court of India has passed a significant judgment regarding interpreting the Most Favoured Nation (MFN) clause in various Indian treaties with OECD member countries. 

The court held that the MFN clause can only be invoked when the third country with which India has a Double Taxation Avoidance Agreement (DTAA) is an OECD member when entering into the DTAA.
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The court also ruled that a separate notification is required for the MFN clause to come into effect. 

Slovenia and Switzerland have ratified a protocol to the tax treaty in effect between the two countries.

The protocol was signed in May 2023, and was ratified on September 28.
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More details would be reported when available.

The international tax community has adopted the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule.

The Convention is an integral part of the Two‐Pillar Solution to Address the Tax Challenges Arising from the Digitalization of the Economy. The Convention, which is now open for signature, represents a major step forward in concluding the work under Pillar Two.

The Subject to Tax Rule (STTR) will enable developing countries to tax certain intra-group payments, in instances where these payments are subject to a nominal corporate income tax rate below 9%. The STTR allows source jurisdictions – those in which covered income arises – to impose a tax where they otherwise would be unable to do so under the provisions of tax treaties.

The text of the Convention, along with an explanatory statement, is available on the OECD’s website.