
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:
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