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Kluwer Law International
ISBN-13
9789403535692
Availability
Ships in 5-7 Business Days
Last Updated
2025-09-19

Overview

About this book:

Schwarz on Tax Treaties, now in its seventh edition, is the definitive analysis of tax treaties from a global perspective and provides in-depth expert analysis of the interpretation and interaction of the interpretation and interaction of United Kingdom and Irish treaty networks with European Union and international law.


This book bridges the gap between academic scholarship and practical guidance in a clear, accessible manner. It is an essential and authoritative reference in the field of international tax law.


What’s in this book:

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; and
  • Exchange 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: doña Sagrario v Administración 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; and
  • CJEU: 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.

How this will help you:

This remarkable book provides expert analysis of all aspects of tax treaties. Authoritative commentary by a globally recognised expert in international taxation and treaty law on judicial decisions and administrative practice around the world on two important treaty networks, provides an all-round international perspective to assist readers concerned with the international aspects of taxation in all states.

Table Of Contents

About the Author


List of Abbreviations


Preface


CHAPTER 1

The Legal Framework: International Law


CHAPTER 2

The Legal Framework: National Law – The United Kingdom; Éire (Ireland)


CHAPTER 3

The Legal Framework: European Law


CHAPTER 4

Interpretation of Tax Treaties


CHAPTER 5

Scope of Tax Treaties: Taxes Covered, Territorial and Temporal Scope


CHAPTER 6

Access to Treaty Benefits: Fiscal Domicile, Personality and Nationality


CHAPTER 7

Permanent Establishment


CHAPTER 8

Distributive Provisions of Income Tax Treaties


CHAPTER 9

Business Profits


CHAPTER 10

Income from Property


CHAPTER 11

Employment and Pensions


CHAPTER 12

Capital Gains


CHAPTER 13

Other Income and Miscellaneous Cases


CHAPTER 14

Treaties and European Tax Directives


CHAPTER 15

Elimination of Double Taxation


CHAPTER 16

Non-discrimination


CHAPTER 17

Treaty Shopping and Other Avoidance


CHAPTER 18

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting


CHAPTER 19

Administration of Treaties


CHAPTER 20

Disputes and Mutual Agreement Procedure


CHAPTER 21

EU Directive on Dispute Resolution and the Arbitration Convention


CHAPTER 22

International Administrative Cooperation


Table of Cases


Table of Legislation


Table of Bilateral Treaties and Model Treaties


Other Treaties and Conventions


Index

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Schwarz on Tax Treaties, Seventh Edition | Wolters Kluwer Legal & Regulatory