ITQ(GloBE) (List) | stevetowers.tax 3/14

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-

137

Key Issues:

Transition rules
Art. 9.1.2
Paras. 8.2 to 8.12 of Comm to Art. 9.1.2.
Deferred tax asset
Government tax incentive
Pre-approval of investment by government agency
Tax depreciation on 200% of investment
Taxpayer choice
Grace Period and Grace Period Limitation

Date uploaded:

June 27, 2025

ITQ G-

135

Key Issues:

Reference Entity: para. 154.1 of Comm to Art. 10.2.1
Reverse Hybrid Entity
Art. 3.5.1(c)
Art. 4.3.2(d)
Para. 59 of Comm to Art. 4.3.2(d)
QDMTT
Para. 118.30 of Comm to definition of QDMTT in Art. 10.1

Date uploaded:

May 23, 2025

ITQ G-

133

Key Issues:

Art. 3.5.1
Art. 10.2.1
“Flow-through Entity” definition in Art. 10.2.1
“Tax Transparent Entity” definition on Art. 10.2.1
Art. 4.3.2(b) & (c)
Reverse Hybrid Entity
Financial Accounting Net Income or Loss
CFC tax
Reference Entity

Date uploaded:

May 2, 2025

ITQ G-

131

Key Issues:

Art. 3.5.1
Art. 10.2.1
“Flow-through Entity” definition in Art. 10.2.1
“Tax Transparent Entity” definition on Art. 10.2.1
Art. 3.5.3
Para. 231 of Comm to Art. 3.5.3
Financial Accounting Net Income or Loss

Date uploaded:

April 11, 2025

ITQ G-

129

Key Issues:

Meaning of “jurisdiction”, for purposes of Jurisdictional Top-up Tax in Art. 5.2
Definition of “location” of Entity in Art. 10.3
Tie-breaker tests in Art. 10.3.4(b)
Federal vs. State taxation

Date uploaded:

March 28, 2025

ITQ G-

127

Key Issues:

Paras. 71.4 to 71.17 of Comm to Art. 4.4.1
Allocation of CFC deferred tax under Art. 4.3.2
Allocation limit in Art. 4.3.3
Art. 4.3.3 ordering rule

Date uploaded:

February 28, 2025

ITQ G-

136

Key Issues:

Securitisation entity
QDMTT
Para. 49.1 of Comm to QDMTT Safe Harbour
Consistency Standard
Switch-Off Rule

Date uploaded:

May 30, 2025

ITQ G-

134

Key Issues:

“Flow-through Entity” definition in Art. 10.2.1
“Tax Transparent Entity” definition in Art. 10.2.1
Jurisdiction does not have CIT
Para. 160 of Comm to Art. 10.2.2
Art. 10.2.4
Para. 169 of Comm to Art. 10.2.5
Hybrid Entity
Financial Accounting Net Income or Loss
Paras. 59 to 59.3 of Comm to Art. 4.3.2(d)

Date uploaded:

May 9, 2025

ITQ G-

132

Key Issues:

Art. 3.5.1
Art. 10.2.1
“Flow-through Entity” definition in Art. 10.2.1
“Tax Transparent Entity” definition on Art. 10.2.1
Art. 4.3.2(b)
Split ownership
Financial Accounting Net Income or Loss
CFC tax

Date uploaded:

April 25, 2025

ITQ G-

130

Key Issues:

Art. 3.5.1
Art. 10.2.1
“Flow-through Entity” definition in Art. 10.2.1
“Tax Transparent Entity” definition on Art. 10.2.1
Comm to Art. 10.2.1: Reference Entity
Art. 3.5.1(b)

Date uploaded:

April 4, 2025

ITQ G-

128

Key Issues:

Election to be exempt from CIT and to pay QDMTT only
Impact of Substance-based Income Exclusion
If election is not made, will CIT qualify as Covered Tax?
Art. 10.1.1 definition of “Tax”: “compulsory”

Date uploaded:

March 21, 2025

ITQ G-

126

Key Issues:

Art. 4.3.2 and Art. 4.3.3
Allocation of Cross-border Deferred Taxes: 5-step process
Paras. 71.4 to 71.17 of Comm to Art. 4.4.1
Art. 4.3.3 limitation
Allocation of CFC tax from Parent Entity to CFC Constituent Entity

Date uploaded:

February 21, 2025