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International Tax Quiz (ITQ)
GloBE rules series
Go to Tax treaty series
Source material
The questions and answers are based on:
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GloBE model rules released by the Inclusive Framework
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Commentary to the GloBE model rules
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GloBE Implementation Framework
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Administrative Guidance to the GloBE model rules
Your comments are very welcome!
I believe in continuous improvement! All your comments (positive and negative!) will be gratefully received – I will take these comments into account in future updates. Please send your comments to: contact@stevetowers.tax. Thank you!
Numbering system
There are currently more than 240 ITQs. They are arranged in 2 series:
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GloBE rules series (ITQ G-001, ITQ G-002, etc.)
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Tax treaty series (ITQ T-001, ITQ T-002, etc.)
ITQ G-
159
Key Issues:
Simplified ETR Safe Harbour
Cross-border allocation of taxes
Art. 432(c): allocation of CFC tax to CFC
Art. 432(e): allocation of dividend withholding tax to dividend-paying company
Chapter 2 of Side-by-Side Package – para. 149: modification of allocation rules
Five-Year Election – para. 157
Date uploaded:
April 17, 2026
ITQ G-
154
Key Issues:
Substance-based Tax Incentive Safe Harbour
Qualified Tax Incentive (QTI)
Qualified Refundable Tax Credit (QRTC)
Is group entitled to make election that QRTC is a QTI?
QRTC can be used against corporate income tax liability (Covered Tax) and against property tax liability (non-Covered Tax)
Date uploaded:
March 2, 2026
ITQ G-
150
Key Issues:
“Intragroup Financing Arrangement” (defined in Art. 10.1.1)
“High-Tax Counterparty” (defined in Art. 10.1.1)
“Low-Tax Entity” (defined in Art. 10.1.1)
Art. 3.2.7
Borrower is highly leveraged: it cannot deduct additional interest expense for local tax purposes
Lender is highly leveraged: it has carried forward previously denied interest expense deductions for local tax purposes
Date uploaded:
November 14, 2025