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International Tax Quiz (ITQ)

Tax treaty series

Go to GloBE rules series

 

Abbreviations and acronyms

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* [YEAR]OECD = OECD model double tax treaty
* [YEAR]UN = UN model double tax treaty
* [YEAR]USMODEL = US model double tax treaty
* TPG = OECD Transfer Pricing Guidelines
* POEM = Place of effective management
* MLI = BEPS Multilateral Instrument
* PPT = Principal purpose test
* Comm = Commentary
* AOA = Authorised OECD Approach
* POAC = Preparatory or auxiliary character

 

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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  T-

009

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Key issues:

  • 2014OECD

  • Art. 11(5), first sentence and second sentence

  • Interest

  • Double foreign tax, double foreign tax credit

More

Date Uploaded:

August 16, 2019

ITQ  T-

007

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Key issues:

  • 2014OECD

  • Art. 8(1)

  • shipping

  • PE – Art. 8(1) vs. Art. 7(1)

  • Art. 11(5), second sentence – loan used for several PEs

  • Interest

More

Date Uploaded:

August 2, 2019

ITQ  T-

005

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Key issues:

  • 2017UN

  • Art. 11(5), second sentence trumps first sentence

  • Art. 7(6)

  • dealt with

  • Arts. 21 vs. 7

  • Bilateral

More

Date Uploaded:

July 19, 2019

ITQ  T-

003

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Key issues:

  • Interest

  • Art. 11(5), second sentence

  • Bilateral

More

Date Uploaded:

July 5, 2019

ITQ  T-

001

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Key issues:

  • G20 membership

More

Date Uploaded:

June 21, 2019

ITQ  T-

008

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Key issues:

  • 2014OECD

  • Land

  • Rent income

  • Arts. 6, 7 & 21

  • Art. 21(2) exception

  • Art. 23A(1)

  • Art. 24(3)

  • Alexander Bosman

  • John Avery Jones

  • Art. 7(1) – narrow view

  • Dhruv Sanghavi

  • Bilateral

More

Date Uploaded:

August 9, 2019

ITQ  T-

006

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Key issues:

  • dual resident (A & B), in receipt of royalties from C

  • which treaty to apply – A/C or B/C

  • Art. 4(3)

  • POEM

  • Art. 12

  • Triangular

More

Date Uploaded:

July 26, 2019

ITQ  T-

004

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Key issues:

  • PE

  • Art. 5(2) – relationship with Art. 5(1) and Art. 5(4)

More

Date Uploaded:

July 12, 2019

ITQ  T-

002

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Key issues:

  • Art. 3(1) defn of “person”

  • Partnership

More

Date Uploaded:

June 28, 2019

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