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Schwarz on Tax Treaties, 5th Edition by SCHWARTZ

Schwarz on Tax Treaties, 5th Edition

By Jonathan Schwarz


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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.

Schwarz on Tax Treaties has established itself as a standard reference work on this challenging subject. The fifth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, international and EU treaty developments including:

  • New Bilateral double tax and exchange of information treaties and protocols
  • OECD BEPS Multilateral Instrument
  • Treaty binding compulsory arbitration
  • State Aid — Luxembourg Alleged aid to McDonald’s
  • Judicial decisions of United Kingdom and foreign courts on UK treaties
  • Taxpayer rights in EU exchange of information
  • Multilateral MOU on Country-By-Country Reporting
  • EU Anti-Tax Avoidance Directive

Case law developments including:

  • UK Supreme Court in Miller, R (oao) v Secretary of State for Exiting the EU
  • Australian High Court in Bywater Investments Ltd and others v CoT
  • Indian Supreme Court in Formula One World Championship Ltd v CIT
  • UK Tax Tribunals Irish Bank Resolution Corporation Ltd v HMRC; Fowler v HMRC; R (oa Derrin Brother Properties Ltd), Vrang v HMRC , Ardmore Construction
  • CJEU in Austria v Germany; Berlioz Investment Fund SA v Directeur de l'administration des Contributions directes; Eqiom SAS and Enka SA v. Ministre des finances et des comptes

Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian Barrister.

Rated Tier 1 by The Chambers Guide to the Legal Profession Jonathan is commended for his ‘encyclopaedic knowledge of double tax treaties’ and is "Highly regarded for his expertise in international tax matters with particular areas of expertise include double tax relief, transfer pricing and cross-border transactions". 

in 2019 he acted for the taxpayer in Martin Fowler v HMRC, a case relating to the UK-South Africa tax treaty. This was one of the main cases discussed in the international tax developments seminar at the IFA Congress 2019 and was widely regarded as a very important case on tax treaty interpretation

He is a visiting Professor at King’s College London and a member of the Permanent Scientific Committee of the International Fiscal Association. He has been listed as a leading tax Barrister in both the Legal 500 for international corporate tax, and he has been lauded in Who's Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. 


Publish Date 03/15/2018
Publish Frequency As Needed
Product Line Kluwer Law International
ISBN 9789041197429
SKU 10058516-0001
Table of Contents

Chapter 1

The legal framework: International law

Chapter 2

The legal framework: European Union law

Chapter 3

The legal framework: United Kingdom law

Chapter 4

Interpretation of tax treaties

Chapter 5

Scope of tax treaties: taxes covered and territorial scope

Chapter 6

Access to treaty benefits: personality, fiscal domicile and nationality

Chapter 7

Permanent establishment

Chapter 8

Distributive provisions of income tax treaties

Chapter 9

Business profits

Chapter 10

Income from property

Chapter 11

Employment and pensions

Chapter 12

Capital gains

Chapter 13

Other income and miscellaneous cases

Chapter 14

Treaties and European tax directives

Chapter 15

Elimination of double taxation

Chapter 16


Chapter 17

Treaty shopping and other avoidance

Chapter 18

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS

Chapter 19

Administration of tax treaties

Chapter 20

Disputes and mutual agreement procedure

Chapter 21

EU international tax dispute resolution directive and arbitration convention

Chapter 22

International administrative cooperation


See what our clients are saying:

“The book is very valuable for any international tax expert, whether inside or outside the United Kingdom.” Anne van de Vijver, Professor of Tax Law, University of Antwerp

"The double tax guru." "Has extraordinary depth of knowledge and experience when it comes to tax treaty issues, and is a creative thinker and a clear and meticulous writer" The Chambers Guide to the Legal Profession 2020