In this new edition of Schwarz on Tax Treaties, recognised authority on international tax Jonathan Schwarz provides expert guidance on the interpretation of UK tax treaties in the context of EC and UK tax law.
With extensive cross references to legislation, cases and other official guidance, this updated edition provides you with all the information you need to deal with double taxation issues.
Contents include:
Application of treaties after the Court of Appeal decision in Smallwood
Characterisation of foreign entities in light of Swift
Updated to reflect the final phase of the rewrite project: TIOPA 2010, CTA 2010
Analysis of European Law revised to reflect the Lisbon treaty
Exchange of information articles and the new OECD standard
The duty to mitigate foreign tax after Bayfine
Insights on resolving dual residence in light of Hankinson, Smallwood and Laerstate
The double taxation treaty passport scheme
2010 UK-German comprehensive treaty
Contents include:
The Legal Framework: United Kingdom Law
The Legal Framework: European Community Law
Interpretation of Treaties
Scope of Tax Treaties: Taxes covered and Territorial
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: Credit for Foreign Tax
Non- Discrimination
Treaty shopping and Other Avoidance
Practical Application
Disputes and Mutual Agreement Procedure
European Arbitration Convention
Mutual Assistance: Exchange of Information and Collection of Taxes
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