Schwarz on Tax Treaties (eBook)

Jonathan Schwarz (Autor)

eBook Download: PDF

2025
Wolters Kluwer (Verlag)
978-94-035-3589-0 (ISBN)

Infos

Schwarz on Tax Treaties is the definitive analysis of tax treaties from a United Kingdom and Irish perspective and provides in-depth expert examination of the interpretation and interaction of those treaty networks with European Union and international law.This edition significantly develops the earlier work with enhanced commentary to include the latest international developments, including:Treaty residence liability to tax and resolution of dual residence;Permanent establishment carrying on business and power of disposal; services PE time threshold;PE profits the Authorised OECD Approach and EU State Aid;Natural resource exploitation income;EU Directive on faster and safer relief of excess withholding taxes; the main purpose or one of the main purposes in determining abuse;CRS Avoidance; Digital Platforms; crypto-assets; Global Minimum Tax; andExchange of information fishing expeditions ; human rights; legal professional privilege.Case law developments cover more than fifty new judicial decisions from around the world, including:UK Supreme Court: Skatteforvaltningen (Danish Tax Administration) v Solo Capital Partners; Royal Bank of Canada v HMRC;Australian High Court and Federal Court: Addy v CoT; Oracle Corporation Australia v CoT;Spanish Supreme Court: dona Sagrario v Administracion General del Estado;German Federal Fiscal Court: Case (I R 47/20)- aircraft engineer;English Court of Appeal: HMRC v GE Financial Investments; Hargreaves Property Holdings v HMRC; BlackRock HoldCo 5, LLC v HMRC;Irish Court of Appeal: Susquehanna International v RC;Indian High Court: International Management Group v CIT; Johnson Matthey v CIT; Shell India Markets v India;UK Tax Tribunals: Burlington Loan Management v HMRC; McCabe v HMRC; Lundberg v First-Tier Tribunal; Oppenheimer v HMRC; HMRC v Aozora GMAC Investment; andCJEU: Airbnb v Agenzia delle Entrate; European Commission v Ireland and Apple; Orde van Vlaamse Balies v Vlaamse Regering; Schneider Electric v Ministre de l Economie.About the AuthorJonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate, and a Canadian and an Irish Barrister. His practice focuses on international tax disputes as counsel and advises on solving cross-border tax problems. Professional appointments have included First Vice President and member of the Permanent Scientific Committee of the International Fiscal Association, as well as the EU Commission Group of experts on removing cross-border tax problems of individuals within the EU. He is a visiting Professor at King s College London. He has been identified as a leading tax Barrister for international corporate tax and expertise in transfer pricing. The Legal 500 has rated him as the leading advisor on international tax treaty issues . In Who s Who Legal UK Bar, he is lauded for brilliant handling of cross-border tax problems . In the Chambers Guide, he is commended for his encyclopaedic knowledge of double tax treaties .

Produkt-Details

• Erscheint lt. Verlag: 23.9.2025
• Sprache: englisch
• Themenwelt: Recht / Steuern ► EU / Internationales Recht
• Themenwelt: Recht / Steuern ► Steuern / Steuerrecht
• ISBN-10: 94-035-3589-X / 940353589X
• ISBN-13: 978-94-035-3589-0 / 9789403535890