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.

The fifth edition significantly develops 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 and exchange of information treaties and protocols
  • OECD BEPS Multilateral Instrument
  • EU Directive on Double Tax Dispute Resolution
  • 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

About the Author

Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a Canadian Barrister, a South African Advocate and an Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems.

He is a visiting Professor at, King’s College London where he is Programme Director of the International Tax Law LLM and an IFA Permanent Scientific Committee member. See www.taxbarristers.com.

He is the Consultant Editor to Croner-i UK Double Tax Treaties. He has been listed as a leading tax Barrister for international corporate tax, and particular expertise in transfer pricing. In the Chambers Guide he is commended for his ‘encyclopaedic knowledge of double tax treaties’ and described as 'clearly amongst the best international tax barristers'. In Who's Who Legal UK Bar 2016, he is lauded for his 'brilliant' handling of cross-border tax problems. In Chambers UK Bar 2018 he is 'highly regarded for his expertise in international tax matters.'  In the Legal 500 UK Bar 2019 he is rated as 'the leading advisor on international tax treaty issues'.