alleryStart learning →Which PE type does the UN Model Tax Convention add, giving more weight to developing countries?
- Insurance PE
- Storage PE
- Service PE
- Branch PE
Show answer and solution
Correct answer: C. Service PE
The UN Model adds the service PE in article 5(3)b.
CA Final Double Taxation — practice questions — page 3
Explore 94 free Double Taxation questions in CA Final Taxation. Open each question or exercise to read its content, reference answers and available explanation.
Practise Double Taxation with Quill →Double Taxation questions and exercises with answers
Showing questions 61–90 of 94.
Which PE type does the UN Model Tax Convention add, giving more weight to developing countries?Read the answer and worked solution →A building site or installation project forms a PE under many treaties only if it does what?Read the answer and worked solution →Whose activities may give rise to an agency PE for the principal?Read the answer and worked solution →Some treaties deem a service PE if services are performed for more than what?Read the answer and worked solution →Which BEPS action addresses the tax challenges of the digital economy?Read the answer and worked solution →In general, tax treaty benefits are available only to whom?Read the answer and worked solution →The UN Model Convention is relevant for treaties with which group?Read the answer and worked solution →Which is a stated goal of entering into a tax treaty?Read the answer and worked solution →A resident may have a PE abroad through a person having authority to do what on its behalf?Read the answer and worked solution →Carrying on business through an independent agent generally results in what?Read the answer and worked solution →Under the OECD tie-breaker for a dual-resident individual, which test applies first?Read the answer and worked solution →With permanent homes in both states, a dual-resident individual is assessed by which test next?Read the answer and worked solution →If a dual-resident has a habitual abode in both or neither state, residence goes to the state of which he is what?Read the answer and worked solution →If an individual is a national of both states or neither, who settles the residence question?Read the answer and worked solution →Until 2017, the OECD Model decided dual company residence by which test?Read the answer and worked solution →In common law jurisdictions, how does domicile relate to residence?Read the answer and worked solution →Residence or citizenship taxation is typically linked with which regime?Read the answer and worked solution →Most tax treaties do what to withholding tax on payments to treaty-country residents?Read the answer and worked solution →Income tax paid to the government by the payer rather than the recipient is called what?Read the answer and worked solution →Withheld tax is typically treated as what toward the recipient's final tax liability?Read the answer and worked solution →Most treaties make special provisions for income of which two groups?Read the answer and worked solution →Treaties requiring help in collecting each other's taxes counter which rule?Read the answer and worked solution →At a minimum, most tax treaties require the countries to do what?Read the answer and worked solution →The usual treaty mechanism to eliminate double taxation requires each country to grant what?Read the answer and worked solution →Foreign tax credit amounts exceeding domestic income tax are usually treated how?Read the answer and worked solution →The usual foreign tax credit cap equals domestic tax on which income?Read the answer and worked solution →Singapore grants foreign tax credit only to whom?Read the answer and worked solution →A deemed paid credit covers taxes paid by which entity on dividends received?Read the answer and worked solution →An advance ruling typically does not bind courts or whom else?Read the answer and worked solution →A ruling may be modified or revoked because of which development?Read the answer and worked solution →
Worked practice questions
A building site or installation project forms a PE under many treaties only if it does what?
- Uses local suppliers
- Exceeds a set budget
- Exceeds a set duration
- Employs 100 workers
Show answer and solution
Correct answer: C. Exceeds a set duration
A construction project becomes a PE only when it lasts longer than a time limit fixed by the treaty.
Whose activities may give rise to an agency PE for the principal?
- A listed auditor
- An independent agent
- A lending banker
- A dependent agent
Show answer and solution
Correct answer: D. A dependent agent
Activities of a dependent agent can create a PE for the principal, unlike an independent agent.
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