A recognised authority on international tax, Jonathan Schwarz is a practicing Barrister and significantly expands on his 2001 work on Tax Treaties: United Kingdom Law, in this 2nd edition of Schwarz on Tax Treaties. With extensive cross references to legislation, cases and other official guidance, this title provides you with all the information you need to deal with double taxation issues. Key features for this edition:
- Application of treaties after the Court of Appeal decision in Smallwood
- Characterisation of foreign entities in light of Swift
- Updated to reflect the final phase of the rewrite project: TIOPA 2010, CTA 2010
- Analysis of European Law revised to reflect the Lisbon treaty
- Exchange of information articles and the new OECD standard
- The duty to mitigate foreign tax after Bayfine
- Insights on resolving dual residence in light of Hankinson, Smallwood and Laerstate
- The double taxation treaty passport scheme
- 2010 UK-German comprehensive treaty
- The Legal Framework: United Kingdom Law
- The Legal Framework: European Community Law
- Interpretation of Treaties
- Scope of Tax Treaties: Taxes covered and Territorial
- Access to Treaty Benefits: Personality, Fiscal Domicile and Nationality
- Permanent Establishment
- Distributive Provisions of Income Tax Treaties
- Business Profits
- Income from Property
- Employment and Pensions
- Capital Gains
- Other Income and Miscellaneous Cases
- Treaties and European Tax Directives
- Elimination of Double Taxation: Credit for Foreign Tax
- Non- Discrimination
- Treaty shopping and Other Avoidance
- Practical Application
- Disputes and Mutual Agreement Procedure
- European Arbitration Convention
- Mutual Assistance: Exchange of Information and Collection of Taxes
