– see also BEPS

365-day holding period

Administration

Agency permanent establishment

Anti-fragmentation

Changes to bilateral treaties

Commissionnaires

Common interpretation

Conference of the parties

Corresponding adjustments, associated enterprises and permanent establishments

Depository

Dividend transfer transactions

Dual resident entities

Effective dispute resolution

Arbitration

Case presentation

Confidentiality

Decisions

Default treatment of costs and

Expenses

Interpretation

Irish position

Last best offer

Mandatory binding

Panel

Procedure

Reasoned opinion

Resolution

UK position

Entry into force and effect

Hybrid mismatches, elimination of double taxation

Deduction but no inclusion(D/NI)

Hybrid transfer

Switch over from exemption to credit

Tax credit duplication

Interpretative materials

Notifications and reservations

Overview

Parties

Permanent establishments in third states

Person closely related to an enterprise

PPT

Preamble

Preparatory or auxiliary exclusions

Preventing treaty abuse

Reference to covered tax agreement

Shares or interests of immovable property entities

Simplified limitation on benefits

Splitting-up of contracts

Synthesised texts

Transparent entities

Withdrawal