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Schwarz on Tax Treaties, 3rd Edition

Schwarz on Tax Treaties, 3rd Edition

Author: Jonathan Schwarz
Publisher: Wolters Kluwer U.K. (formerly CCH)
ISBN: 9781847986375
Published In: August 2013
Format: Paperback , 599 pages
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

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Schwarz on tax treaties is the definitive analysis of tax treaties from a UK perspective and provides in depth expert analysis of the interpretation and interaction of the UK's treaty network with EU and international law in their application to UK tax law.

Jonathan Schwarz is a pre-eminent authority on international taxation, a leading barrister in this area and a visiting Professor at King's College, London. Schwarz on Tax Treaties has quickly established itself as the standard reference work on this challenging subject.

The third edition significantly expands the earlier work with enhanced commentary and is updated to include the latest UK treaty developments, international and EU law including:

New Bilateral double tax treaties and protocols between the United Kingdom and China, India, Ethiopia, Liechtenstein, the Netherlands, Spain, Barbados and others
Administrative cooperation agreement with Switzerland
FATCA agreement with the United States and FATCA type agreements with the Channel Islands and the Isle of Man
Bank levy treaties with Germany and the Netherlands
Judicial decisions of United Kingdom and foreign courts on UK treaties
Latest treaty anti-abuse and limitation of benefit articles
Impact of the GAAR introduced by Finance Act 2013 on tax treaties
New OECD Model Article 7 profit attribution in UK treaties
Case law developments including:

US tax court in Retief Goosen
Court of Appeal on Anson, Ben Nevis and FCE Bank
Haseldine, HSBC Holdings and Bank of New York, Weiser and Yates
CJEU in National Grid Indus, Foggia, Scheuten Solar Technology, Belvedere Costruzioni and Ji?í Sabou

Key benefits:

Specific focus on the UK tax treaty network and law relating to it.
Expert commentary on the common forms of treaty provisions dealing with double taxation relief.
Identifies and examines variations of some of the more unusual treaty provisions.
Explains both UK and foreign case law that consider both the OECD model and other treaties.
Extensive cross references to legislation, cases and other official guidance to give comprehensive and authoritative commentary on all aspects of working with tax treaties.

Reviews of earlier editions:

"...The most thorough analysis of treaty anti-abuse measures by combining a comprehensive scrutiny of the extensive UK case law and a truly international perspective."
Nicola Saccardo- Maisto e Associati, London

"...the subject matter is sometimes complex, but Schwarz has succeeded in bringing light and clarity to difficult issues."
Eric Osterweil- Steptoe & Johnson LLP -Brussels International Tax Report (July/August 2002)