Jonathan S. Schwarz

Jonathan Schwarz focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems.

• Double tax relief, tax treaties, transfer pricing, permanent establishments, Diverted Profits Tax, Digital Services Tax, cross-border corporate and commercial transactions, withholding taxes, residence, domicile, EU tax law, property investment, exploitation of intellectual property and digital economy taxation, shipping, air transportation and tonnage tax;
• Internationally mobile employees and cross-border and pensions, entertainers and sportspeople;
• Cross-border joint ventures and private equity, group structures, finance, CFCs, investment funds and management taxation;
• Treaty mutual agreement procedures as well as tax-related commercial and investment treaty arbitration;
• International tax enforcement and exchange of information.

Further details of his work at www.taxbarristers.com.

Education, Professional Memberships and Appointments

BA, LLB (Witwatersrand)

LLM (UC Berkeley)

CTA(Fellow)

Barrister, England & Wales (Middle Temple)

Barrister, Republic of Ireland

Barrister and Solicitor, Alberta, Canada

Advocate, South Africa

Directories - Professional Recommendations

Jonathan has been consistently listed as a leading tax Barrister by reference to recommendation for international corporate tax and particular expertise in transfer pricing in Chambers' Guide to the Legal Profession and the Legal 500. In the Chambers Guide he is commended for his ‘encyclopaedic knowledge of double tax treaties’ and described as “clearly amongst the best international tax barristers”. In Who's Who Legal UK Bar 2016, he is lauded for his “brilliant handling of cross-border tax problems”. In Chambers UK Bar 2018 he is “highly regarded for his expertise in international tax matters.”  In the Legal 500 UK Bar 2019 he is rated as “the leading advisor on international tax treaty issues.” In Chambers UK Bar 2020 he is identified as "The double tax guru" with “extraordinary depth of knowledge and experience when it comes to tax treaty issues, and is a creative thinker and a clear and meticulous writer." In Chambers UK Bar 2021: Tax and Tax Private Client he is noted for having "a lot of specialist knowledge about how international tax works." and being  "very thorough, knows his stuff and is easy to work with." In the Legal 500 UK Bar 2022: Tax and Private Client he is noted as "....incredibly knowledgeable on international taxation. I find that he knows the area inside out and is quick to provide an opinion." and  "...a leading expert in international tax matters (he literally wrote the book) and has an encyclopedic knowledge of tax treaties." In the Chambers and Partners 2022: Tax and Private Client guides he is noted as "He is very thorough, knows his stuff and is easy to work with." "He is good at explaining complex issues." "Has encyclopedic knowledge, and devotes so much time and energy to his clients." "He is very practical and user-friendly with clients." In Chambers & Partners 2023 "Joanthan is highly regarded for his expertise in international tax matters. His particular areas of expertise include double tax relief, tax treaties, transfer pricing and cross-border transactions. He is also qualified as a barrister in Canada and South Africa"

"Jonathan is extremely thorough and approaches tax issues in a structured and principles-based manner." "A guru on matters of international tax law."

Recent Cases

Fowler v HMRC [2020] UKSC 22

Bundeszentralamt Für Steuern v MF Global UK Limited (in special administration) [2019] EWHC 705 (Ch)

Publications

Books:

Schwarz on Tax Treaties (Wolters Kluwer): definitive, in-depth analysis of tax treaties under UK EU and international law.

Booth and Schwarz: Residence, Domicile and UK Taxation (Bloomsbury Professional): the leading work on residence of individuals, companies, partnerships and trusts.

Convenio de doble imposición México – Reino Unido, Mexico – United Kingdom Double Tax Convention, http://amzn.to/3hZCaCe with Jorge Correa (Thompson Reuters): Spanish and English compilation of the Mexico-UK treaty and related documents including the authors’ synthesized text of the treaty as it will be modified by the OECD BEPS Multilateral Convention.

Recent Articles:

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)

Permanent Establishment Profit Attribution: United Kingdom Courts Examine the ”Authorised OECD Approach” (Bulletin for International Taxation, 2019 (Volume 73), No. 6/7)

Other Experience

Visiting Professor at the Dickson Poon School of Law, King’s College London and Programme Director of the International Tax Law LLM.

International Fiscal Association - Permanent Scientific Committee 

EU Commission Group of experts on removing tax problems facing individuals who are active across borders within the EU (June 2014 to November 2015)

Additional Information

Read Jonathan’s blog

Twitter: @SchwarzTax

Further details at www.taxbarristers.com

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