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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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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-

017

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Key issues:

  • 2014OECD

  • Negative interest

  • Art. 11(3)

  • Penalty fee paid to bank

More

Date Uploaded:

October 11, 2019

ITQ  T-

015

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Key issues:

  • 2014OECD

  • PE

  • Profits attributable to PE, loss

  • Art. 7(1)

  • Significant people functions

  • Dredging project

  • 2010 OECD Art. 7 report

More

Date Uploaded:

September 27, 2019

ITQ  T-

013

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Key issues:

  • 2014OECD

  • Art. 6

  • Land, rent income

  • Interest

  • Art. 11(5), first sentence

  • PE

  • Triangular

More

Date Uploaded:

September 13, 2019

ITQ  T-

011

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Key issues:

  • 2014OECD

  • Partnership, transparent, company, hybrid

  • Art. 1

  • Art. 13(5)

  • RCF case

  • Triangular

  • Conflict of qualification

More

Date Uploaded:

August 30, 2019

ITQ  T-

009

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Key issues:

  • 2014OECD

  • Art. 11(5), first sentence and second sentence

  • Interest

  • Double foreign tax, double foreign tax credit

More

Date Uploaded:

August 16, 2019

ITQ  T-

007

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Key issues:

  • 2014OECD

  • Art. 8(1)

  • shipping

  • PE – Art. 8(1) vs. Art. 7(1)

  • Art. 11(5), second sentence – loan used for several PEs

  • Interest

More

Date Uploaded:

August 2, 2019

ITQ  T-

016

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Key issues:

  • 2014OECD

  • Conflict of attribution of income

  • Domestic anti-abuse provision, impact on treaty

  • J. Wheeler, “The missing keystone of income tax treaties”

  • Unresolved economic double taxation

More

Date Uploaded:

October 4, 2019

ITQ  T-

014

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Key issues:

  • Partnership

  • Transparent, company, hybrid

  • 2014OECD

  • Art. 13(2)

  • PE

  • Art. 23B

  • Conflict of qualification

More

Date Uploaded:

September 20, 2019

ITQ  T-

012

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Key issues:

  • 2011UN

  • Dividends

  • Art. 10(2)

  • Dividend-paying company is non-resident

  • Art. 10(5)

  • Art. 1

  • Madeira & Neves, “Exploring the boundaries of the application of Article 10(5) of the OECD Model”

  • See also ITQ091

  • Art. 21(3)

  • Triangular

More

Date Uploaded:

September 6, 2019

ITQ  T-

010

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Key issues:

  • 2014OECD

  • Art. 24(3)

  • Foreign tax credit for PE, forced by Art. 24(3)

  • Art. 23B(1)

  • Triangular

More

Date Uploaded:

August 23, 2019

ITQ  T-

008

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Key issues:

  • 2014OECD

  • Land

  • Rent income

  • Arts. 6, 7 & 21

  • Art. 21(2) exception

  • Art. 23A(1)

  • Art. 24(3)

  • Alexander Bosman

  • John Avery Jones

  • Art. 7(1) – narrow view

  • Dhruv Sanghavi

  • Bilateral

More

Date Uploaded:

August 9, 2019

ITQ  T-

006

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Key issues:

  • dual resident (A & B), in receipt of royalties from C

  • which treaty to apply – A/C or B/C

  • Art. 4(3)

  • POEM

  • Art. 12

  • Triangular

More

Date Uploaded:

July 26, 2019

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