Tax treaty series

International Tax Quiz (ITQ)

Abbreviations and acronyms

* [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-

005

Key issues:

2017UN
Art. 11(5), second sentence trumps first sentence
Art. 7(6)
dealt with
Arts. 21 vs. 7
Bilateral

Date Uploaded:

July 19, 2019

ITQ T-

003

Key issues:

Interest
Art. 11(5), second sentence
Bilateral

Date Uploaded:

July 5, 2019

ITQ T-

001

Key issues:

G20 membership

Date Uploaded:

June 21, 2019

ITQ T-

004

Key issues:

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

Date Uploaded:

July 12, 2019

ITQ T-

002

Key issues:

Art. 3(1) defn of “person”
Partnership

Date Uploaded:

June 28, 2019