Schwarz on Tax Treaties, 3rd Edition

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.