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International Tax Quiz (ITQ)

Tax treaty series

Go to GloBE rules series

 

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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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-

065

Key issues:

  • 2001UN

  • Art. 24: non-discrimination

  • “Good faith” rule in Art. 26, Vienna Convention on Law of Treaties

  • Can treaties increase tax liabilities?

Date Uploaded:

November 13, 2020

ITQ  T-

063

Key issues:

  • Impact of TP adjustment on treaty treatment of royalties

  • PPT (Art. 29(9))

Date Uploaded:

October 30, 2020

ITQ  T-

061

Key issues:

  • 2008OECD

  • Intra-entity “transaction” between PE and head office

  • Art. 7(2)

  • Art. 7(3)

  • Interest on “internal loan”

Date Uploaded:

October 16, 2020

ITQ  T-

059

Key issues:

  • 2017OECD

  • Art. 24: non-discrimination

Date Uploaded:

October 2, 2020

ITQ  T-

057

Key issues:

  • 2017OECD

  • Hybrid entity

  • Art. 1(2)

Date Uploaded:

September 18, 2020

ITQ  T-

055

Key issues:

  • 2017UN

  • Transfer pricing

  • Imputed interest on interest-free loan

  • Art. 11

  • Art. 21

  • Art. 7

Date Uploaded:

August 28, 2020

ITQ  T-

064

Key issues:

  • 2010OECD

  • PE

  • “Significant economic presence” rule introduced into domestic law

  • Online streaming

  • Art. 3(2)

Date Uploaded:

November 6, 2020

ITQ  T-

062

Key issues:

  • 2010OECD

  • 2001UN

  • MLI

  • Equity swaps

  • Beneficial ownership

  • PPT

  • Art. 21(3)

Date Uploaded:

October 23, 2020

ITQ  T-

060

Key issues:

  • 2017OECD

  • MLI

  • PPT

  • Domestic law GAAR

Date Uploaded:

October 9, 2020

ITQ  T-

058

Key issues:

  • MLI

  • Capital gains tax on sales of shares in “land-rich” companies

  • Vienna Convention on Law of Treaties

Date Uploaded:

September 25, 2020

ITQ  T-

056

Key issues:

  • 2017UN

  • PE

  • Art. 5(1): “at the disposal”

  • Art. 5(4)

  • Art. 5(5)(a)

  • Art. 7: “modified force of attraction”

Date Uploaded:

September 4, 2020

ITQ  T-

054

Key issues:

  • 2017OECD

  • Art. 13: computation of “gain”

  • Art. 23A

Date Uploaded:

August 21, 2020

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