Jonathan Schwarz, BA, LLB (Witwatersrand) LLM (University of California, Berkeley), Barrister of the Middle Temple; Advocate of the High Court of South Africa; Barrister and Solicitor, Alberta, Canada; Fellow of the Chartered Institute of Taxation

Visiting Professorial Fellow

Jonathan Schwarz practices as an English Barrister at Temple Tax Chambers in London. His practice focuses on international tax planning and tax disputes involving international issues. His areas of specialisation include cross-border mergers, acquisitions and reorganisations, investment funds and management, private equity, shipping including tonnage tax, transfer pricing and supply chain structuring, CFCs, double tax relief; internationally mobile employees, sports people and entertainers and UK non-domiciled residents, tax treaties and EU law affecting taxation.

He has been listed as a leading tax Barrister in both the Legal 500 by reference to recommendation for international corporate tax, and Chambers' Guide to the Legal Profession by reference to international transactions and particular expertise in transfer pricing.

He is a vice president of the International Fiscal Association and Chairman of the European Branch of the Chartered Institute of Taxation.

In May 2009 he chaired a session at the OECD’s International Tax Seminar for Judges and has chaired several seminars at the annual congresses of the International Fiscal Association including on Business Restructuring, EC law and Exit Taxes, and on Abuse of Law in EC Law. In November 2008 he gave the 16th Hardman Memorial Lecture for the Tax Faculty of the ICAEW. He is a member of the editorial advisory board of Business Law International and was the United Kingdom’s participant on the 2005-2006 joint OECD-IFA research project on Practical Application of Tax Treaties.

His teaching subjects on the LLM programme relate to his professional practice including various aspects of tax treaties, transfer pricing, cross-border mergers and acquisitions, international investment funds, and remedies for breach of EC law. He also teaches at the International Tax Academy of the International Bureau of Fiscal Documentation in Amsterdam in The Netherlands.

Publications:

Key Publications

• Schwarz on Tax Treaties
  CCH UK –WoltersKluwer UK Limited
  417 pages, Softcover
  ISBN 978-1-84798-057-1
• Annotated UK Double Tax Treaties (CCH Blue Book 2009) (Consultant Editor)
  CCH UK –WoltersKluwer UK Limited
  Softcover 1000 pages
  ISBN: 978-1-84798-056-4
• Booth: Residence, Domicile and UK Taxation 13th Edition (link to page Booth)
  Tottel Publishing Limited
  270 Pages. Soft cover
  ISBN: 978 1 84766 128 9
• Transfer Pricing and Business Restructurings: Streamlining all the way (Contributor)
  ISBN:  978-90-8722-055-6
  520 pages, softcover
  a new book providing the key tax and transfer pricing concepts, methodologies and trends relating to business restructurings.
• Blackstone’s Employment Law Practice, 2006, 2007, 2008, 2009 (Chapter 29: Tax Treatment of Tribunal Awards and Compromises
  Oxford University Press
• Tax Treaties: United Kingdom Law and Practice
  Sweet and Maxwell (2002)
  385 pages, Hardcover
  ISBN 0421 72490 0

Selected Articles since 2001

• 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 Taxation - Volume 63 Number 5/6
  July 2009, p 245
• Abuse and European Union Tax Law
  Bulletin for International Taxation - Volume 62 Number 12
  December 2008 p 289
• The Need and Scope for Coordination of Tax Policies in the EU
  Bulletin for International Taxation - 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