Mergers Directive
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