eBook Schwarz on Tax Treaties 6th Edition By Jonathan Schwarz
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eBook Schwarz on Tax Treaties 6th Edition By Jonathan Schwarz

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The Schwarz on Tax Treaties 6th Edition By Jonathan Schwarz

  1. The Legal Framework: International Law – Foundation of tax treaties under public international law.
  2. The Legal Framework: National Law – Focuses specifically on domestic implementation in the United Kingdom and Éire (Ireland).
  3. The Legal Framework: European Law – Overlap of treaty law with broader European legal principles.
  4. Interpretation of Tax Treaties – Mechanics of how courts construe treaty language and contextual terminology.
  5. Scope of Tax Treaties – Analysis of covered taxes, alongside territorial and temporal scope limitations.
  6. Access to Treaty Benefits – Deep dive into corporate and individual eligibility involving fiscal domicile, personality, and nationality.
  7. Permanent Establishment (PE) – Detailed rules on what constitutes a fixed place of business.
  8. Distributive Provisions of Income Tax Treaties – Classification and mechanics of how taxing rights are allocated.
  9. Business Profits – Rules governing the attribution of commercial profits, including permanent establishments.
  10. Income from Property – Treatment of immovable property and real estate revenues.
  11. Employment and Pensions – Cross-border taxation of mobile employees, directors, and retirement schemes.
  12. Capital Gains – Allocation of taxing rights on the disposal of assets.
  13. Other Income and Miscellaneous Cases – Catch-all sweep for income categories not explicitly defined elsewhere.
  14. Treaties and European Tax Directives – Interplay between bilateral tax agreements and mandatory EU directives.
  15. Elimination of Double Taxation – Domestic and treaty-based mechanism relief systems (e.g., credit and exemption methods).
  16. Non-discrimination – Protecting foreign nationals and entities from discriminatory domestic tax treatments.
  17. Treaty Shopping and Other Avoidance – Anti-abuse doctrines, limitation on benefits, and structural tax avoidance prevention.
  18. Multilateral Convention (MLI) – Impact of the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (BEPS).
  19. Administration of Treaties – Practical processes, filing requirements, and treaty claims.
  20. Disputes and Mutual Agreement Procedure (MAP) – Competent authority procedures for resolving treaty deadlocks.
  21. EU Directive on Dispute Resolution and the Arbitration Convention – Specialized formal arbitration options within Europe.
  22. International Administrative Cooperation – Frameworks for information exchange, joint audits, and mutual assistance.
Key Content Updates Specific to the 6th Edition
  • BEPS Multilateral Instrument (MLI): Comprehensive analysis of Covered Tax Agreements modified by the BEPS framework.
  • Brexit Implications: Detailed evaluation of the EU-UK Trade and Cooperation Agreement.
  • Digital Economy Changes: Early frameworks on Digital Services Tax (DST) and emerging attribution rules.
  • Taxpayer Rights: Protections under international regimes during the exchange of information and cross-border collections.
  • Transparency Directives: Analysis of the EU DAC 6 disclosure rules regarding cross-border arrangements.
  • Binding Arbitration: Evolving legal standards for treaty-based compulsory arbitration.

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Topics

Access to Treaty Benefits BEPS Multilateral Instrument MLI Brexit Implications Digital Economy Changes Disputes and Mutual Agreement Procedure MAP Distributive Provisions of Income Tax Treaties Elimination of Double EU Directive on Dispute Resolution and the Arbitration Convention International Administrative Cooperation Interpretation of Tax Treaties Legal Framework International Law Other Income and Miscellaneous Cases Permanent Establishment PE Scope of Tax Treaties Treaties and European Tax Directives Treaty Shopping and Other Avoidance
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