ITQ(GloBE) (List) | stevetowers.tax 11/13

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

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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-

031

Key Issues:

Art. 6.2.1(d) & (e)
Payroll carve-out
Art. 5.3.3
Tangible asset carve-out
Art. 5.3.4
Substance-based Income Exclusion
Constituent Entity transferred from one MNE Group to another MNE Group

Date uploaded:

September 30, 2022

ITQ G-

029

Key Issues:

Definition of “Transition Year” in Art. 10.1.1
Art. 9.1.1
Art. 9.1.2, deferred tax asset for carry forward tax loss at start of Transition Year
Permanent difference in calculating tax loss
Deferred tax balances at start of Transition Year
UTPR

Date uploaded:

September 16, 2022

ITQ G-

027

Key Issues:

Carry-back of tax losses
Additional Current Top-up Tax
Art. 4.1.5
Art. 4.6.1

Date uploaded:

August 26, 2022

ITQ G-

025

Key Issues:

Art. 4.5
GloBE Loss Election
Additional Current Top-up Tax
Art. 4.1.5
Carry forward of tax loss
Total Deferred Tax Adjustment Amount
Art. 4.1.2(b)
GloBE Loss Deferred Tax Asset
Art. 4.4.2(c)
Art. 4.4.1

Date uploaded:

August 12, 2022

ITQ G-

023

Key Issues:

Current tax expense
Deferred tax expense
Art. 4.4.1
Total Deferred Tax Adjustment Amount
15% recast
Depreciation of fixed asset

Date uploaded:

July 29, 2022

ITQ G-

021

Key Issues:

Exemption from IIR tax under Art. 1.1.3
REIT
“Excluded Entity” definition in Art. 1.5.1
Art. 1.5.1(e): Real Estate Investment Entity that is a UPE
Art. 1.5.1(f): Investment Fund that is a UPE
Immovable property: shares in land-rich company
Investor in REIT is tax-exempt pension fund

Date uploaded:

July 1, 2022

ITQ G-

030

Key Issues:

Art. 6.1.1
Art. 6.1.2: definition of “merger”
Art. 6.1.3: definition of “demerger”
Art. 1.1.1
Consolidated revenue threshold test, in context of merger and demerger

Date uploaded:

September 23, 2022

ITQ G-

028

Key Issues:

Impact of permanent differences (between taxable profits and GloBE Income) on Top-up Tax: high statutory corporate income tax rates (25% & 30%), but still Top-up tax
Current tax expense
Total Deferred Tax Adjustment Amount

Date uploaded:

September 9, 2022

ITQ G-

026

Key Issues:

Carry forward tax losses
Additional Current Top-up Tax (Art. 4.1.5)
Permanent difference between GloBE Loss and tax loss
Total Deferred Tax Adjustment Amount
Art. 4.4.2(c)

Date uploaded:

August 19, 2022

ITQ G-

024

Key Issues:

Deferred tax expense
Deferred tax liability reverses in Year 10
“Percentage of completion” vs. “completed contracts”: recognition of profit on long-term project
Art. 4.4.4: recaptured deferred tax liability
Top-up Tax
Art. 4.4.5 not applicable
Art. 4.4.7
“paid” vs. “reversed”
Art. 4.4.2(a)
Additional Current Top-up Tax

Date uploaded:

August 5, 2022

ITQ G-

022

Key Issues:

Sovereign wealth fund is UPE
“Governmental Entity” definition in Art. 10.1.1
“Excluded Entity” definitions in Art. 1.5.1 and Art. 1.5.1(b)
“at least 85%” test in Art. 1.5.1(b)
Art. 1.1.1: exempt from GloBE rules
UTPR

Date uploaded:

July 22, 2022

ITQ G-

020

Key Issues:

Trust is UPE
“Entity” definition in Art. 10.1.1 – trust Deemed para. (d) Consolidated Financial Statements – definition in Art. 10.1.1
Revenue threshold in Art. 1.1.1
Non-12 months accounting period: adjustment of revenue threshold in Art. 1.1.2
Application of IIR to IPE

Date uploaded:

June 24, 2022