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OECD refers to:
Model Tax Treaties are developed by:
Model Tax treaties are:
Model Tax treaties act as __________ for entering into tax treaties
First draft of model convention applicable to all countries was prepared by –
OECD Model Convention is a model treaty between two-
OECD Model Convention advocates-
UN Model convention is a model treaty between-
UN Model Convention is based on –
UN Model Convention gives more weightage to:
UN Model convention encourages flow of ___________from developed countries to developing countries
UN Model takes into account sharing tax revenue with country providing-
US Model Convention is applied by-
OECD and UN Model Conventions would apply to taxes on-
Based on OECD and UN Model conventions, taxes apply to which of the following cases?
The concept of ‘Resident of Contracting State’ assumes significance in which of the following scenarios?
As per the OECD model , a building, construction or installation project constitutes a Permanent Establishment if it lasts for more than:
As per the UN model , an assembly and installation project constitutes a Permanent Establishment if it lasts for more than:
The concept of Service PE is present in:
In order to be considered as a Service PE, the activities of nature furnishing services by an enterprise through employees or personnel engaged by the enterprise, are to continue within a contracting state for a period aggregating more than ________ in any __________ period commencing or ending in the fiscal year concerned.
The basic rule for PE is expressed in Article 5(1) in case of:
Which among the following is considered as Permanent Establishment in terms of Article 5(2)?
Article 5(6) relating to Insurance Enterprise is covered under:
PE of an insurance enterprise is determined under OECD Model in accordance with provisions of:
As a general rule, Business profits of an enterprise can be taxed:
Right of Source State to tax business profits of an enterprise exists only if:
As per OECD Model Convention, once a PE is proven, the Source state can tax:
UN Model specifies about taxability of profits in source state through the principle of:
As per the Force of Attraction rule prescribed by UN Model, when a foreign enterprise sets up a PE in source state, which of the following can be taxed by source state?
As a general rule, interest income is taxed in:
As per OECD Model, if the beneficial owner of interest is resident of other Contracting state, then tax charged on gross amount of such interest should not exceed:
As per UN Model, if the beneficial owner of interest is resident of other Contracting state, then tax charged on gross amount of such interest should not exceed:
As per OECD Model, royalties arising in Source State and beneficially owned by a resident of Residence State are taxable:
As per UN Model, royalties are taxable:
As per UN Model, if the beneficial owner of royalty is resident of Residence state, then tax charged by Source state should not exceed:
What is the sequence of Tie breaker rule to determine residential status in case where an individual is resident of both contracting states as per domestic laws of the contracting states?
The concept of dual residence arises where:
Which among the following are not considered as interest as per OECD and UN Model Conventions?
Which among the following are excluded from the meaning of Fees for Technical services under UN Model?
Right to tax capital gains may be:
Right to tax capital gains are conferred to Source state if more than ________ of value of shares during preceding _________ is derived from immovable property in such source state.
Right to tax other income under OECD Model is conferred to:
Which among the following are methods to eliminate double taxation under Model Conventions?
The methods to eliminate double taxation under Model conventions are___________ to each other:
Where a tax payer believes that the treatment accorded by either or both of the Contracting states is not accordance with the provisions of the treaty, which among the following is the dispute resolution process prescribed by UN Model Convention?