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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:

  • 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-

005

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Key Issues:

  • Definition of Covered Taxes 

  • Art. 4.2.1 

  • Art. 4.2.2 

  • Tax on income or profits, net basis 

  • Tax “in lieu of” tax on income 

  • Withholding tax 

  • CFC taxation 

  • Qualified Domestic Top-up Tax 

  • Wealth tax

More

Date uploaded:

February 11, 2022

ITQ G-

003

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Key Issues:

  • Computation of GloBE Income or Loss 

  • Refundable tax credit vs. non-refundable 

  • Intragroup financing arrangement (Art. 3.2.7) 

  • Impairment accounting (Art. 3.2.5) 

  • “High-Tax Counterparty” definition (Art. 10.1.1)

More

Date uploaded:

January 21, 2022

ITQ G-

001

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Key Issues:

  • Computation of GloBE Income or Loss 

  • Net Taxes Expense 

  • Other Comprehensive Income 

  • Accrued and received dividend income 

  • Expenses related to Excluded Dividends 

  • Excluded Equity Gain or Loss 

  • Covered Taxes shown as contra to particular revenue items

More

Date uploaded:

January 7, 2022

ITQ G-

004

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Key Issues:

  • Computation of GloBE Income or Loss 

  • Main Entity and PE: Art. 3.4 

  • Definition of PE in Art. 10.1.1: contract-concluding agency PE 

  • Art. 7 in OECD model vs. UN model: modified force of attraction rule 

  • Charter fee: Art. 3.3 

  • Election to apply consolidated accounting treatment: Art. 3.2.8

More

Date uploaded:

January 28, 2022

ITQ G-

002

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Key Issues:

  • Computation of GloBE Income or Loss 

  • Included Revaluation Method Gain or Loss Merger 

  • GloBE Reorganisation 

  • Excluded Equity Gain or Loss 

  • Prior Period Errors and Changes in Accounting Principles 

  • Accrued Pension Expense 

  • Transfer pricing adjustment (Art. 3.2.3)

More

Date uploaded:

January 14, 2022

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