Schwarz on Tax Treaties
6th Edition Wolters Kluwer
The definitive analysis of tax treaties. In-depth expert analysis of the interpretation and application of tax treaties under International, EU, UK and Irish tax law.
Booth and Schwarz: Residence, Domicile and UK Taxation
21st Edition Bloomsbury Professional Publishing Ltd
The leading work on the tax residence of individuals, companies, partnerships and trusts.
Transfer Pricing and Business Restructurings: Streamlining all the way
IBFD
Contributor to a book providing the key tax and transfer pricing concepts, methodologies and trends relating to business restructurings.
Convenio de doble imposición México – Reino Unido, Mexico – United Kingdom Double Tax Convention
With Jorge Correa
Spanish and English compilation of the Mexico-UK double taxation treaty its protocol and other related documents including the authors’ synthesized text of of the treaty as it will be modified by the OECD BEPS Multilateral Convention.
Scope of Arbitration under the OECD and UN Model Provisions
In Dispute Resolution under Tax Treaties and Beyond, (Chapter 10), Maisto, G ed, 2023 IBFD.
MAP and Arbitration for Financial Transactions under the Current Treaty Framework: OECD and UN Perspective
In Applying the Arm’s Length Principle to Intra-Group Financial Transactions, Danon, R et al eds, 2023 Wolters Kluwer.
Current Issues in the Use of OECD and UN Commentaries in Tax Treaty Interpretation
In Building Global International Tax Law (Chapter 2), P Pistone ed, 2022 IBFD.
Croner-i UK Double Tax Treaties
Consultant editor to online database of consolidated and annotated UK tax treaties.
Taxation of immovable property from a common law perspective
In Immovable Property under Domestic Law, EU Law and Tax Treaties (Chapter 2), G Maisto ed, 2015 IBFD.
Tax Treatment of Tribunal Awards and Compromises
In: Blackstone’s Employment Law Practice (Chapter 29) 2007 to 2011
Tax issues which most frequently arise for employment practitioners
“… a useful and succinct chapter on the tax treatment of awards and compromises which I would recommend to all employment lawyers…”
Philip Wood, Dawsons, reviewing the book in ELA Briefing 9 November 2004
Selected Articles
European Commission v Apple and Ireland – opinion of Advocate General
Taxation, 14 December 2023
This article evaluates the Opinion of Advocate General Pitruzzella on whether Irish rulings on the attribution of profits to Irish branches of non-resident companies constituted illegal state aid in light of the Court of Justice judgement in Fiat Chrysler Finance Europe v Commission and Advocate General Kokott’s Opinion in Engie Global LNG Holding Sàrl and Luxembourg v European Commission.
Article 3(2) of the OECD and UN Models: An International View
Bulletin for International Taxation, 2021 (Volume 75), No. 1
This article sets out the case for an international interpretation of article 3(2) (General definitions) of the OECD Model Treaty by reference to the UK judicial decisions in Fowler v HMRC, including the text of argument submitted to the Supreme Court.
Implementation of the Principal-Purpose Test as Part of the Multilateral Instrument: Canadian and Foreign Perspectives
With Penny Woolford and Stephanie Smith
Canadian Tax Foundation, 2019 Conference Report, 28:1 - 17
The Impact of the New Preamble on the Interpretation of Old and New Treaties and on the Policy of Abuse Prevention
Bulletin for International Taxation, 2020 (Volume 74), No. 4/5
This article examines the effect of the new preamble to tax treaties introduced into existing tax treaties by the OECD Multilateral Instrument and in tax treaties that follow the OECD and UN Models (2017) with regard to preventing abuse, by reference to relevant case law.
Permanent Establishment Profit Attribution: United Kingdom Courts Examine the ”Authorised OECD Approach”
Bulletin for International Taxation, 2019 (Volume 73), No. 6/7
This article, considers the implications of the functionally separate enterprise concept under the Authorised OECD Approach to the attribution of profits to permanent establishments with reference to tax treaties as analysed in two UK tax cases, Irish Bank Resolution (2017) and Bloomberg Inc (2018).
Austria v Germany: Concept of ‘debt-claims with participation on profits’ excludes genusscheine
Highlights and Insights on European Taxation H&I 2017/12.406
Multilateral Instrument on BEPS
23 May 2017
This video explains why the multilateral instrument has been introduced, what it's designed to achieve and how it will affect bilateral treaties.
Corporate Tax and Treaty Consequences of Brexit
Tax Management International Journal, 46 TM International Journal 76, 2/10/17.
Copyright 2017 by The Bureau of National Affairs, Inc. Reproduced with permission. (800-372-1033)
Diverted Profits Tax and its Impact on Corporate Structure
25 June 2015
This video discusses the tax charges that involve permanent establishments and intra-group transactions, highlighting new compliance risks and the impact of the tax on international corporate group structures.
Beneficial ownership in double tax treaties
A note about the meaning and application of the term "beneficial ownership" in double tax treaties.
EU State Aid investigations into Apple, Starbucks and Fiat
Tax Journal, 20 June 2015
Macklin: World Bank pensions and treaty interpretation
Tax Journal, 17 April 2015
BEPS Treaty abuse-related actions
Tax Journal, 12 December 2014
UK and EU Approaches to Treaty Shopping
Canadian Tax Journal (2014) 62:3 729 – 39
EU State Aid investigation into Apple, Starbucks and Fiat
Tax Journal, 20 June 2014
Tax Treaty Interpretation after Ben Nevis
Bulletin for International Fiscal Documentation - Volume 66 Number 4/5
January 2014, p 295
Cross-border Termination Payments
Tax Adviser, November 2013
Double Taxation in the European Single Market
Bulletin for International Fiscal Documentation - Volume 66 Number 4/5
April 2012, p 295
Avoidance and Tax Treaties: Current UK Experience
Bulletin for International Fiscal Documentation - Volume 65 Number 8
September 2011, p 453
Rights and Powers: Protecting the Legitimate Interests of Taxpayers
British Tax Review [2009] (No 3) 307
EC Remedies for National Law in Breach of EC Law: The United Kingdom's Experience
Bulletin for International Fiscal Documentation - Volume 63 Number 5/6
July 2009, p 245
Abuse and European Union Tax Law
Bulletin for International Fiscal Documentation - Volume 62 Number 12
December 2008 p 289
The Need and Scope for Coordination of Tax Policies in the EU
Bulletin for International Fiscal Documentation - Volume 61 Number 7
December 2007 p262
Unwinding Sandwich Structures from the Standpoint of the Country of the Acquirer (or Surviving Merger Party)
With Nathan Boidman and others
Tax Notes International – 13 December 2004 April 10, 2006,
Re-engineering Multinational Supply Chains
with Elina Castro
Bulletin for International Fiscal Documentation - Volume 60 Number 5
December 2006, p 187
Spin-Offs and Split Offs
With Nathan Boidman and others
Tax Notes International – 13 December 2004
Unwinding or Otherwise Dealing with “Sandwich” Structures Resulting from an International Merger or Acquisition
With Nathan Boidman and others
Tax Notes International – 10 May 2004
Transfer Pricing – The New Regime
TAXline Tax Planning 2004-2005 - Chapter 25
October 2004
Personal Taxation under the European Court of Justice Microscope
Bulletin for International Fiscal Documentation - Volume 58 Number 12 2004
December 2004
Permanent Establishments
TAXline Tax Planning 2003-2004 - Chapter 19 October 2003
European Corporate Group Structures and Financing: The Impact of European Court Decisions and European Legislative Development
Bulletin for International Fiscal Documentation - Volume 57 Number 11 2003
November 2003
Intra-Europe Exchange of Direct Tax Information: The Directive on Mutual Assistance 25 Years On
The EC Tax Journal - Volume 6, 2002 - Issue 1
April 2002
European Commission Strategy for Company Taxation in the European Community
Bulletin for International Fiscal Documentation
2002
Current European Community Law Issues in Direct Taxation
Chapter in TAXline Tax Planning 2002-2003
2002
Current Issues under European Community Law on Cross-Border Dividends
Bulletin for International Fiscal Documentation - Volume 55 Number 2 2001
February 2001
Transfer Pricing - Recent Developments
TAXline Tax Planning 2000-2001 - Chapter 22
October 2000
Book Review: Practical Guide to US Transfer Pricing by Robert T. Cole
IBFD International Transfer Pricing Journal - Volume 7 Number 3 2000
May/June 2000
Cross-Border Corporate Structures and Financing:
The Impact of European Court Decisions on Tax Discrimination
Bulletin for International Fiscal Documentation - Volume 54 Number 3 2000
March 2000
Transfer Pricing and Electronic Commerce
Bulletin for International Fiscal Documentation - Volume 53 Number 7 1999
July 1999
Current Issues in Transfer Pricing
TAXline Tax Planning 1999-2000 - Chapter 7
June 1999
What Do The New UK Transfer Pricing Rules Mean?
Bulletin for International Fiscal Documentation - Volume 53 Number 2 1999
February 1999