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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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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  T-

081

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Key issues:

  • 2014OECD

  • Art. 5(5)

  • authority to conclude contracts

  • Valueclick case

  • Paras. 32.1 and 33 2014 OECD Comm

  • Art. 7

  • Profit attributable to agency PE

  • AOA

  • ostensible authority

Date Uploaded:

March 26, 2021

ITQ  T-

079

​

Key issues:

  • 2014OECD

  • Art. 13: alienation

  • Appreciation in value

  • Option fee

Date Uploaded:

March 12, 2021

ITQ  T-

077

​

Key issues:

  • 2014OECD

  • Partnership

  • Art. 10

  • Beneficial ownership

  • Art. 1: abuse of treaty

Date Uploaded:

February 26, 2021

ITQ  T-

075

​

Key issues:

  • 2017OECD

  • Art. 6

  • Art. 11

  • Royal Bank of Canada

Date Uploaded:

February 5, 2021

ITQ  T-

073

​

Key issues:

  • 2017UN

  • Art. 12: royalties

  • Art. 21

  • Art. 7

  • Germany

Date Uploaded:

January 22, 2021

ITQ  T-

071

​

Key issues:

  • 2017OECD

  • Transfer pricing rules

  • Art. 9

  • Art. 7

  • Corresponding adjustment

Date Uploaded:

January 8, 2021

ITQ  T-

080

​

Key issues:

  • 2014OECD

  • PE

  • Home office

  • Art. 5(1): “at the disposal”

  • Art. 5(4): POAC

Date Uploaded:

March 19, 2021

ITQ  T-

078

​

Key issues:

  • 2017OECD

  • Redeemable preference shares: treated as shares or debt-claims?

  • Art. 10

  • Art. 11

Date Uploaded:

March 5, 2021

ITQ  T-

076

​

Key issues:

  • 2017OECD

  • Art. 8: international shipping

  • Art. 7

  • Art. 13

Date Uploaded:

February 19, 2021

ITQ  T-

074

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Key issues:

  • 2000OECD

  • PE

  • Art. 7(3)

  • Art. 24: non-discrimination

Date Uploaded:

January 29, 2021

ITQ  T-

072

​

Key issues:

  • 2017OECD

  • Branch profits remittance tax

  • Art. 7

  • Art. 24: non-discrimination

Date Uploaded:

January 15, 2021

ITQ  T-

070

​

Key issues:

  • 2017OECD

  • Branch vs. subsidiary

Date Uploaded:

December 18, 2020

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