Dividends, limitation of benefits

Commentary – Schwarz on Tax Treaties ¶18-100

Dual residence

Commentary – Schwarz on Tax Treaties ¶14-200

Entities

Administrative practice

Commentary – Schwarz on Tax Treaties ¶14-050

Classification

Commentary – Schwarz on Tax Treaties ¶14-050

Fiscal transparency

Commentary – Schwarz on Tax Treaties ¶14-050

Foreign entity characterisation

Commentary – Schwarz on Tax Treaties ¶14-050

Personality

Commentary – Schwarz on Tax Treaties ¶14-050

Transparent

Commentary – Schwarz on Tax Treaties ¶14-050

Entitlement

Commentary – Schwarz on Tax Treaties ¶14-000

Extension of

Commentary – Schwarz on Tax Treaties ¶10-700

Foreign entity characterisation

Commentary – Schwarz on Tax Treaties ¶14-050

Interest paid, limitation of benefits

Commentary – Schwarz on Tax Treaties ¶18-150

Limitation

– see Avoidance; Treaty shopping

Most favoured nation treatment

Commentary – Schwarz on Tax Treaties ¶11-050

Nationality

Commentary – Schwarz on Tax Treaties ¶14-300

Neutralising discrimination

Commentary – Schwarz on Tax Treaties ¶11-250

Non-residents

Commentary – Schwarz on Tax Treaties ¶11-050

Personality

Commentary – Schwarz on Tax Treaties ¶14-050

Residence

Commentary – Schwarz on Tax Treaties ¶14-100–Schwarz on Tax Treaties ¶14-250

Royalties, limitation of benefits

Commentary – Schwarz on Tax Treaties ¶18-200

Saving clause

Commentary – Schwarz on Tax Treaties ¶14-250

Transparent entities

Commentary – Schwarz on Tax Treaties ¶14-050

Treaty shopping

– see Treaty shopping

Treaty under-ride

– see Treaty under-ride