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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:
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GloBE rules series (ITQ G-001, ITQ G-002, etc.)
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Tax treaty series (ITQ T-001, ITQ T-002, etc.)
ITQ T-
027
Key issues:
2014OECD
Real estate investment business
Acquisition and sale (at profit) of call option to purchase land in B
Art. 13(1)
Is option “immovable property”?
Defn of “immovable property”, Art. 6(2)
Is option “situated in” B?
“In the money” call option
ITQ T-
028
Key issues:
1997OECD: 1st X/Y treaty
2014OECD: 2nd X/Y treaty
Purchase of shareholding in YCo before 1st X/Y treaty signed: YCo not land-rich at time of purchase
Sale of shareholding in YCo after 2nd X/Y treaty signed: YCo land-rich at time of sale
Para. 3.1, OECD Comm on Art. 13
ITQ T-
022
Key issues:
2014OECD
PE, Art. 5(1), Art. 5(3), measurement of time of site or project
Phases of construction
Temporary interruption
Swedish Supreme Administrative Court case
Jerome Monsenego, “The Construction PE and Temporary Interruptions: Questions Based on a Swedish Case”