top of page
14.png

International Tax Quiz (ITQ)

GloBE rules series

Go to Tax treaty 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-

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

More

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

More

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

More

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

More

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

More

Date uploaded:

July 1, 2022

ITQ G-

019

Key Issues:

  • Art. 2.6.1 

  • Art. 2.4.1 

  • Art. 2.4.2 

  • Art. 2.6.3 

  • Art. 2.6.4 

  • UTPR Percentage

More

Date uploaded:

June 17, 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

More

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)

More

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

More

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

More

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

More

Date uploaded:

June 24, 2022

ITQ G-

018

Key Issues:

  • Art. 2.5.2 

  • Art. 2.5.3 

  • UTPR Top-up Tax 

  • IIR Top-up Tax

More

Date uploaded:

June 10, 2022

bottom of page