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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:
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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-
123
Key Issues:
Paras. 80 to 82.7 of Comm to Art. 4.4.1
Substitute Loss Carry-forward DTA (SLCDTA)
Does SLCDTA include foreign tax credits (FTCs) related to royalties?
Hybrid Entity
How to determine which FTCs relate to Hybrid Entity and which relate to royalties – pro rata approach
Date uploaded:
January 24, 2025
ITQ G-
121
Key Issues:
Allocation of cross-border current taxes under Art. 4.3.2
Step 2 of 4-step process: “Allocable Covered Taxes”
Cross-crediting regime
Hybrid Entity
Qualified Refundable Tax Credit: impact on deemed domestic source income
Disregarded payment: impact on deemed domestic source income
Date uploaded:
December 13, 2024
ITQ G-
117
Key Issues:
Change of residence treated as “transfer of assets” for purposes of Art. 9.1.3: para. 10.3 of Comm to Art. 9.1.3
Transitional CbCR Safe Harbour: impact on start of “Transition Year”
GloBE carrying value
Deferred tax asset for GloBE purposes: paras. 10.8.1 & 10.8.2 of Comm to Art. 9.1.3
Date uploaded:
November 8, 2024
ITQ G-
124
Key Issues:
Amount B
If Amount B applies in distribution jurisdiction for CIT purposes, must it also apply in distribution jurisdiction for determining GloBE Income?
If Amount B applies in distribution jurisdiction, can distribution jurisdiction also impose UTPR tax?
Date uploaded:
February 7, 2025
ITQ G-
120
Key Issues:
Allocation of cross-border current taxes under Art. 4.3.2
Step 1 of 4-step process: determining “foreign source income”
Cross-crediting regime
Hybrid Entity
Treatment of: (1) disregarded income, and (2) domestic source income, for purposes of Art. 4.3.2 allocation
Date uploaded:
December 6, 2024
ITQ G-
118
Key Issues:
Does Art. 9.1.3 apply to an intra-entity “transfer” of assets from the head office to a branch (i.e., from the Main Entity to a PE)?
Transitional CbCR Safe Harbour: impact on start of “Transition Year” for purposes of Art. 9.1.3
Art. 6.3.2 (GloBE Reorganisation) does not apply before Transition Year
Date uploaded:
November 15, 2024