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 South African Advocate and a Canadian 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 the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500 for international corporate tax, and Chambers’ Guide to the Legal Profession for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his “brilliant” handling of cross-border tax problems. In Chambers Guide he is commended for his ‘encyclopaedic knowledge of double tax treaties’.