ITQ(GloBE) (List) | stevetowers.tax

International Tax Quiz (ITQ)

GloBE rules series

Source material

The questions and answers are based on:

GloBE model rules released by the Inclusive Framework
Commentary to the GloBE model rules
GloBE Implementation Framework
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:

GloBE rules series (ITQ G-001, ITQ G-002, etc.)
Tax treaty series (ITQ T-001, ITQ T-002, etc.)

ITQ G-

154 NEW

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-

152

Key Issues:

Side-by-Side Safe Harbour (SbS SH)
Election not made in jurisdiction because of unrecognized PE – is SbS SH effective in that jurisdiction?
UTPR – allocation formula in Art. 2.6.1

Date uploaded:

January 23, 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

ITQ G-

148

Key Issues:

“Local Tangible Assets” definition in Art. 10.1.1
Parcels of land sold for loss and gain
Art. 3.2.6 election
Carry back of Aggregate Asset Gain for Look-back Period (5 years)
Set off against prior year loss (Net Asset Loss)

Date uploaded:

October 31, 2025

ITQ G-

146

Key Issues:

Shares acquired on different dates
“Portfolio Shareholding” definition in Art. 10.1.1
“Short-term Portfolio Shareholding” definition in Art. 10.1.1
“Excluded Dividends” definition in Art. 10.1.1
Impact on GloBE Income

Date uploaded:

October 17, 2025

ITQ G-

144

Key Issues:

Intermediate Parent Entity (definition in Art. 10.1.1)
Art. 2.1.2
Inclusion Ratio (Art. 2.2.2 & Art. 2.2.3)
Allocable Share
Art. 2.3.1 & Art. 2.3.2

Date uploaded:

September 19, 2025

ITQ G-

153

Key Issues:

Side-by-Side Safe Harbour (SbS SH)
IIR imposed on POPE
Impact of SbS SH on IIR, UTPR, and QDMTT

Date uploaded:

January 30, 2026

ITQ G-

151

Key Issues:

Art. 3.3.1
International Shipping Income
Qualified Ancillary International Shipping Income (QAISI)
Art. 3.3.4: 50% cap on QAISI
Impact on GloBE Income

Date uploaded:

November 28, 2025

ITQ G-

149

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
Hybrid instrument: debt for financial accounting purposes, equity for tax purposes

Date uploaded:

November 7, 2025

ITQ G-

147

Key Issues:

Shares acquired on different dates
Ordering rule for sold shares
“Portfolio Shareholding” definition in Art. 10.1.1
“Short-term Portfolio Shareholding” definition in Art. 10.1.1
“Excluded Dividends” definition in Art. 10.1.1
Impact on GloBE Income

Date uploaded:

October 24, 2025

ITQ G-

145

Key Issues:

Intermediate Parent Entity (definition in Art. 10.1.1)
Allocable Share
Art. 2.2
UTPR
Art. 2.5.2 & Art. 2.5.3
UTPR Jurisdictions (definition in Art. 10.1.1)
Art. 2.6.1

Date uploaded:

October 6, 2025

ITQ G-

143

Key Issues:

POPE and Intermediate Parent Entity (definitions in Art. 10.1.1)
Art. 2.1.4
Inclusion Ratio (Art. 2.2.2 & Art. 2.2.3)
Allocable Share
Art. 2.3.1 & Art. 2.3.2

Date uploaded:

September 12, 2025