Schwarz on tax treaties / Jonathan Schwarz (BA, LLB (Witwatersrand), LLM (University of California, Berkeley, FTII, Barrister, Advocate of the High Court of South Africa, Barrrister and Solicitor, Alberta, Canada)
The legal framework : international law -- The legal framework : United Kingdom law -- The legal framework : European law -- Interpretation of tax treaties -- Scope of tax treaties : taxes covered, territorial, and temporal scope -- Access to treaty benefits : fiscal domicile, personality, 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 -- Non-discrimination -- Treaty shopping and other avoidance -- Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting -- Administration of treaties -- Disputes and mutual agreement procedure (MAP) -- EU directive on dispute resolution and the Arbitration Convention -- International administrative cooperation.
Summary
Schwarz on tax treaties is an 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, international, and EU treaty developments.