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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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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-

053

Key issues:

  • 2017OECD

  • Transfer pricing

  • Accurate delineation of transaction

Date Uploaded:

August 14, 2020

ITQ  T-

051

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

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

Key issues:

  • 2017OECD

  • Art. 24: non-discrimination

Date Uploaded:

June 26, 2020

ITQ  T-

045

Key issues:

  • “Most favoured nation” provision

  • Contracting State becomes member of OECD after bilateral treaty entered into force

  • Art. 12: royalties

Date Uploaded:

June 12, 2020

ITQ  T-

043

Key issues:

  • 2017OECD

  • Art. 29(9): PPT

  • Art. 23A & 23B

  • “thickly capitalised”: no debt

Date Uploaded:

May 22, 2020

ITQ  T-

052

Key issues:

  • 2017OECD

  • PE

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

Date Uploaded:

August 7, 2020

ITQ  T-

050

Key issues:

  • 2014OECD

  • PE

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

  • Apparent (ostensible) authority

Date Uploaded:

July 17, 2020

ITQ  T-

048

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

ITQ  T-

044

Key issues:

  • 2017OECD

  • Influencer on social media

  • Art. 17

  • Art. 7

  • Art. 21

Date Uploaded:

May 29, 2020

ITQ  T-

042

Key issues:

  • 2014OECD

  • Transfer pricing

  • Art. 9

  • Art. 11(6)

  • Secondary adjustment

Date Uploaded:

May 15, 2020

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