Dividends, limitation of benefits

Commentary – Schwarz on Tax Treaties 22.13

Dual residence

Commentary – Schwarz on Tax Treaties 6.05

Entities

Administrative practice

Commentary – Schwarz on Tax Treaties 6.02

Classification

Commentary – Schwarz on Tax Treaties 6.02

Fiscal transparency

Commentary – Schwarz on Tax Treaties 6.02

Foreign entity characterization

Commentary – Schwarz on Tax Treaties 6.02

Personality

Commentary – Schwarz on Tax Treaties 6.02

Transparent

Commentary – Schwarz on Tax Treaties 6.02

Entitlement

Commentary – Schwarz on Tax Treaties 3.03

Extension of

Commentary – Schwarz on Tax Treaties 2.17

Foreign entity characterisation

Commentary – Schwarz on Tax Treaties 6.02

Interest paid, limitation of benefits

Commentary – Schwarz on Tax Treaties 17.13

Most favoured nation treatment

Commentary – Schwarz on Tax Treaties 3.03

Nationality

Commentary – Schwarz on Tax Treaties 3.09

Neutralising discrimination

Commentary – Schwarz on Tax Treaties 3.07

Non-residents

Commentary – Schwarz on Tax Treaties 6.07

Personality

Commentary – Schwarz on Tax Treaties 6.02

Residence

Commentary – Schwarz on Tax Treaties 6.03Schwarz on Tax Treaties 6.08

Royalties, limitation of benefits

Commentary – Schwarz on Tax Treaties 17.13

Saving clause

Commentary – Schwarz on Tax Treaties 6.06

Transparent entities

Commentary – Schwarz on Tax Treaties 6.02

Treaty shopping

– see Treaty shopping

Treaty under-ride

– see Treaty under-ride