.png)
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
Your comments are very welcome!
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-
030
Key issues:
2010OECD
Procurement office of XCo
PE
5(1)
5(4)(d)
Meaning of “purchasing”
Are identification of potential suppliers and due diligence part of “purchasing”?
“solely”
Procurement services performed for XSub: XCo has PE (failure of “solely”) – but no profits attributable to PE (Art. 7(5))
XSub has PE (Art. 5(5)) – but no profits attributable to PE (Art. 7(5))