Description
The definitive analysis of tax treaties with comprehensive commentary on their interpretation and practical application as well as interaction with EC and UK tax law benefiting from the author's extensive experience in this area of tax.
- Authoritative – benefit from the author’s extensive experience of this area
- Comprehensive- detailed exposition of tax treaties from a UK perspective
- Unique- the only book dedicated to explaining the UK tax treaty network
- Up to date- the latest UK and EC tax treaty developments and the 2008 OECD Model Convention
- The ideal companion to CCH’s Annotated Tax Treaties 2008-09 – combine the full database of treaties with in-depth commentary for easy access to all the information a tax adviser needs effectively solve cross-border taxation.
The author – Jonathan Schwarz BA LLB LLM FTII, is a practicing Barrister and recognised authority on international tax. This extensively updates and expands on his 2001 book ‿Tax Treaties: United Kingdom Law and Practice’ including the latest developments. An indispensable guide to the UK treaty network and related law for tax practitioners.
The work is organised as follows:
- The legal framework: United Kingdom law
- The legal framework: European law
- Interpretation of tax treaties
- Access to treaty benefits: fiscal domicile and personality
- Income from business
- Permanent establishements
- Income from property and investment
- Employment and pensions
- Capital gains
- Miscellaneous cases
- Non- discrimination
- Treaties and European Directives
- Elimination of double taxation: credit for foreign tax
- Treaty shopping and other avoidance
- Practical application
- Disputes and mutual agreement procedure
- Transfer Pricing Arbitration Convention
- Exchange of information
- Cross- border tax collection
Extensive cross-references to legislation, cases and other official guidance are provided.
"I would strongly recommend any tax practitioner operating in the international arena to purchase this book." Malcolm Finney - Taxation, 16 July 2009
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Jonathan Schwarz
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