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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-

057

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Key issues:

  • 2017OECD

  • Hybrid entity

  • Art. 1(2)

Date Uploaded:

September 18, 2020

ITQ  T-

055

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Key issues:

  • 2017UN

  • Transfer pricing

  • Imputed interest on interest-free loan

  • Art. 11

  • Art. 21

  • Art. 7

Date Uploaded:

August 28, 2020

ITQ  T-

053

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Key issues:

  • 2017OECD

  • Transfer pricing

  • Accurate delineation of transaction

Date Uploaded:

August 14, 2020

ITQ  T-

051

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Key issues:

  • 2017OECD

  • Sale of patent in consideration for annual fee set at 5% of purchaser’s sales revenue

  • Art. 12: royalties

  • Art. 13

  • Art. 11

  • Art. 29(9): PPT

Date Uploaded:

July 24, 2020

ITQ  T-

049

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Key issues:

  • 2017OECD

  • Total return swap in regard to building and government securities

  • Art. 6

  • Art. 7

  • Art. 21

  • Art. 29(9): PPT

Date Uploaded:

July 10, 2020

ITQ  T-

047

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Key issues:

  • 2017OECD

  • Art. 24: non-discrimination

Date Uploaded:

June 26, 2020

ITQ  T-

056

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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

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Key issues:

  • 2017OECD

  • Art. 13: computation of “gain”

  • Art. 23A

Date Uploaded:

August 21, 2020

ITQ  T-

052

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Key issues:

  • 2017OECD

  • PE

  • Art. 5(6): independent agent acting in ordinary course of business

Date Uploaded:

August 7, 2020

ITQ  T-

050

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Key issues:

  • 2014OECD

  • PE

  • Art. 5(5): authority to conclude contracts

  • Apparent (ostensible) authority

Date Uploaded:

July 17, 2020

ITQ  T-

048

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Key issues:

  • 2017OECD

  • PE

  • Liaison office

  • Art. 5(1)

  • Art. 5(4)

  • Art. 7

Date Uploaded:

July 3, 2020

ITQ  T-

046

​

Key issues:

  • 2017UN

  • Construction project

  • PE

  • Art. 5(3)(a)

  • Measuring time: temporary interruption

  • Art. 7

Date Uploaded:

June 19, 2020

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