– see also Double taxation relief

Aim of

Commentary – Schwarz on Tax Treaties ¶10-150

Avoidance and abuse of law

Commentary – Schwarz on Tax Treaties ¶11-350

Benefits

– see Benefits of treaties

Binding upon parties

Commentary – Schwarz on Tax Treaties ¶10-550

Charging income or gains

Commentary – Schwarz on Tax Treaties ¶10-250

Compensation for breach of European law

Commentary – Schwarz on Tax Treaties ¶11-450

Construction principle

Commentary – Schwarz on Tax Treaties ¶10-250

Definition of treaty

Commentary – Schwarz on Tax Treaties ¶10-050

Discrimination

Authorising discrimination

Commentary – Schwarz on Tax Treaties ¶11-150

Generally

Commentary – Schwarz on Tax Treaties ¶11-200

Neutralising

Commentary – Schwarz on Tax Treaties ¶11-250

Distributive provisions

Commentary – Schwarz on Tax Treaties ¶16-000

Domestic law

Commentary – Schwarz on Tax Treaties ¶10-250 ; Schwarz on Tax Treaties ¶11-025

Double taxation abolition

Commentary – Schwarz on Tax Treaties ¶10-250 ; Schwarz on Tax Treaties ¶11-100

Draft

Commentary – Schwarz on Tax Treaties ¶10-100

Effect

Generally

Commentary – Schwarz on Tax Treaties ¶10-400

Limits on

Commentary – Schwarz on Tax Treaties ¶11-100

Entry into force

Commentary – Schwarz on Tax Treaties ¶10-450 ; Schwarz on Tax Treaties ¶9-350

Estates, inheritance and gift tax

Commentary – Schwarz on Tax Treaties ¶13-025

European law

– see European law

Extension of treaty benefits

Commentary – Schwarz on Tax Treaties ¶10-700

Impact of European law

Commentary – Schwarz on Tax Treaties ¶11-000

Implementation

Domestic law

Commentary – Schwarz on Tax Treaties ¶10-250

Generally

Commentary – Schwarz on Tax Treaties ¶10-200

International law

Commentary – Schwarz on Tax Treaties ¶10-250

Scope of

Commentary – Schwarz on Tax Treaties ¶10-250

Incorporation into domestic law

Commentary – Schwarz on Tax Treaties ¶10-250

Interpretation

– see Interpretation of tax treaties

Law of

Commentary – Schwarz on Tax Treaties ¶9-350

Limiting access to treaty benefits

Commentary – Schwarz on Tax Treaties ¶10-650

Non-discrimination provisions

Commentary – Schwarz on Tax Treaties ¶10-250

Non-residents

Tax credits

Commentary – Schwarz on Tax Treaties ¶10-250

Treaty benefits

Commentary – Schwarz on Tax Treaties ¶11-050

Non-treaties

Generally

Commentary – Schwarz on Tax Treaties ¶10-050

Tax rules

Commentary – Schwarz on Tax Treaties ¶10-175

Observance of

Commentary – Schwarz on Tax Treaties ¶9-350

Old law, made under

Commentary – Schwarz on Tax Treaties ¶10-350

Overriding provisions

Commentary – Schwarz on Tax Treaties ¶10-600

Pacta sunt servanda principle

Commentary – Schwarz on Tax Treaties ¶10-250 ; Schwarz on Tax Treaties ¶10-550

Power to make

Commentary – Schwarz on Tax Treaties ¶10-100

Precedence over domestic law

Commentary – Schwarz on Tax Treaties ¶10-550

Procedure for making

Commentary – Schwarz on Tax Treaties ¶10-100

Putative

Commentary – Schwarz on Tax Treaties ¶10-450

Ratification

Commentary – Schwarz on Tax Treaties ¶10-200 ; Schwarz on Tax Treaties ¶10-450

Relationship with specific statutory provisions

Commentary – Schwarz on Tax Treaties ¶10-550

Relief from income or corporation tax

Commentary – Schwarz on Tax Treaties ¶10-250

Restrictions

Defences to

Commentary – Schwarz on Tax Treaties ¶11-300

Effect on

Commentary – Schwarz on Tax Treaties ¶11-150

Retrospective effect

Commentary – Schwarz on Tax Treaties ¶10-300

Revocation

Commentary – Schwarz on Tax Treaties ¶10-300

Role of

Commentary – Schwarz on Tax Treaties ¶11-100

Scope of

Commentary – Schwarz on Tax Treaties ¶10-150 ; Schwarz on Tax Treaties ¶13-000

Sovereignty, changes in

Commentary – Schwarz on Tax Treaties ¶10-500

State succession

Commentary – Schwarz on Tax Treaties ¶10-500

Tax credits for non-residents

Commentary – Schwarz on Tax Treaties ¶10-250

Taxes covered

Commentary – Schwarz on Tax Treaties ¶13-025

Temporal scope

Commentary – Schwarz on Tax Treaties ¶13-100

Termination

Commentary – Schwarz on Tax Treaties ¶9-350

Territorial scope

Commentary – Schwarz on Tax Treaties ¶13-050

Third countries

Distinction between member states and

Commentary – Schwarz on Tax Treaties ¶11-100

EU treaties with

Commentary – Schwarz on Tax Treaties ¶11-500

Generally

Commentary – Schwarz on Tax Treaties ¶11-400