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. Jonathan Schwarz is a pre-eminent authority on international taxation, a leading barrister in this area and a visiting Professor at King's College, London. Schwarz on Tax Treaties has quickly established itself as the standard reference work on this challenging ...
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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. Jonathan Schwarz is a pre-eminent authority on international taxation, a leading barrister in this area and a visiting Professor at King's College, London. Schwarz on Tax Treaties has quickly established itself as the standard reference work on this challenging subject. Whatand#8217;s new for 2015-16? Legislative developments, latest case law and new treaties with key trading partners, including: The Supreme Court decision in Anson v HMRC UK Finance Act changes in 2015, such as the Diverted Profits Tax and non-resident disposals Amendments to the EU Parent-Subsidiary Directive The impact of the OECD Model Convention and Commentary 2014 Protocols with Canada, China and Germany, Protocol and Exchange of Letters with Japan Contents include: The legal framework: international law The legal framework: European Union law The legal framework: United Kingdom Law Interpretation of tax treaties Scope of tax treaties: taxes covered and territorial scope 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 Non-discrimination Treaty shopping and other avoidance Administration of tax treaties Disputes and mutual agreement procedure EU arbitration convention International administrative cooperation Key benefits: Specific focus on the UK tax treaty network and law relating to it. Expert commentary on the common forms of treaty provisions dealing with double taxation relief. Identifies and examines variations of some of the more unusual treaty provisions. Explains both UK and foreign case law that consider both the OECD model and other treaties. Extensive cross references to legislation, cases and other official guidance to give comprehensive and authoritative commentary on all aspects of working with tax treaties. andquot;... The most thorough analysis of treaty anti-abuse measures by combining a comprehensive scrutiny of the extensive UK case law and a truly international perspective. andquot; Nicola Saccardo- Maisto e Associati, London
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