Parent-Subsidiary Directive
Aim
Commentary –
Schwarz on Tax Treaties ¶22-250
Avoidance
Commentary –
Schwarz on Tax Treaties ¶22-450
Directive shopping
Commentary –
Schwarz on Tax Treaties ¶22-450
Dividends
Commentary –
Schwarz on Tax Treaties ¶22-250
Elimination of double taxation
Commentary –
Schwarz on Tax Treaties ¶22-250
Implementation
Commentary –
Schwarz on Tax Treaties ¶22-250
Interaction with treaties
Commentary –
Schwarz on Tax Treaties ¶22-250
Inward-bound distributions
Commentary –
Schwarz on Tax Treaties ¶22-250
Outward-bound distributions
Commentary –
Schwarz on Tax Treaties ¶22-250
Permanent establishment
Commentary –
Schwarz on Tax Treaties ¶22-250
Qualification requirements
Commentary –
Schwarz on Tax Treaties ¶22-250
Real estate investment trusts
Commentary –
Schwarz on Tax Treaties ¶22-250
Transparent entities
Commentary –
Schwarz on Tax Treaties ¶22-250