Benefits of treaties
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
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