Cash consideration

Commentary – Schwarz on Tax Treaties ¶22-400

Losses

Commentary – Schwarz on Tax Treaties ¶22-400

Permanent establishment

Commentary – Schwarz on Tax Treaties ¶22-400

Purpose

Commentary – Schwarz on Tax Treaties ¶22-350

Qualifying entities

Commentary – Schwarz on Tax Treaties ¶22-350

Qualifying transactions

Commentary – Schwarz on Tax Treaties ¶22-350

Shareholders

Commentary – Schwarz on Tax Treaties ¶22-400

Unrealised gains

Commentary – Schwarz on Tax Treaties ¶22-400