SECTION A: CONCEPTS AND LAW

No.	Tax statements and scenarios	TRUE, FALSE, YES, NO, AMOUNT, REQUIRED ANSWER
1	DTA is ONLY about elimination of international double taxation
2	3 types of international double taxation exists
3	BEPS has 14 action points
4	FDI, generally, is the first step on internationalization process
5	OECD Model is more supportive of developing country interests

SECTION B: BASE EROSION PROFIT SHIFTING (BEPS)

Explain the following terms and concepts in the context of BEPS action points:

1. Beneficial ownership
2. Tax arbitrage
3. Artificial PE
4. Hybrid Mismatches
5. Tax Shelters
6. Thin Capitalization
7. Harmful Tax Practices
8. Country by Country Reporting
9. Covered Tax Agreements
10. Compulsory Arbitration
11. Multilateral Instrument
12. Principal Purpose Test
13. Limitation of Benefits

SECTION C: DOUBLE TAX AGREEMENTS

Explain the following terms and concepts in the context of Double Tax Agreement:

1. Tax Sparing
2. Tie-breaker rules
3. Centre of Vital Interest
4. Business Profits
5. Residency clash
6. Source clash
7. Commissionaire agents
8. Associated Enterprises
9. Corresponding Adjustments
10. Fiscal evasion
11. Assistance In Collections
12. Country of Source
13. Country of Residence
14. Mutual Agreement Procedure
15. Taxing Rights
16. Non-Discrimination
17. Exchange of Information

SECTION D: APPLICATION QUESTIONS

1. Explain two types of international double taxation and by making reference to tax treaties, explain how these double taxation situations can be resolved and eliminated?

2. Explain how the credit and exemption methods by reference to Fijis Income Tax Act provide some examples on these?

3. Whats the linkage between Permanent Establishment and Business Profits Articles in DTAs?

4. Explain two types of incomes on which taxing rights between country of source and country of residence is shared?

5. Explain all the BEPS action points relating to Transfer Pricing?

6. From BEPS persepective, evaluate the statement Digital Economy is the Economy

SECTION E : CASE STUDIES

1. Compare and contrast Fijis Double Tax Agreements with 13 countries with OECD Model Convention and state tax treaty issues.

2. Explain tax sparing positions in treaties?

3. With examples, explain how section 60 of the Fiji Income Tax Act work?

4. Using internet research, explain what led to the termination of Double Tax Agreement between Netherlands and Mongolia