Shows
International Tax BitesEpisode 85.. Part 2 of closing in on promoters of marketed tax avoidanceIn the Spring Statement the Chancellor announced a consultation on reforming the rules around marketed tax avoidance schemes. In this two Part Bonus Episode Harriet and Grahame take a deep dive into the consultation documents.2025-04-1836 minInternational Tax BitesEpisode 84 Part 1 of closing in on promoters of marketed tax avoidanceIn the Spring Statement the Chancellor announced a consultation on reforming the rules around marketed tax avoidance schemes. In this two Part Bonus Episode Harriet and Grahame take a deep dive into the consultation documents.2025-04-141h 14International Tax BitesEp. 83 Familiar Concepts and Pillar 2: Exchange of Info and CbCRIn this episode Harriet and Grahame discuss the interaction of Pillar 2 and the Country by Country Reporting regime. How does CbCR drive Pillar 2 and why is it a vital building block for the OECD's flagship anti-avoidance package?2025-04-1034 minInternational Tax BitesEpisode 82 - Familiar Concepts and Pillar 2 - Source of Income and GainsIn this episode Harriet and Grahame review the concept of source, where does it come from, how do you determine the source of certain types of income and gains and then discuss how this foundational concept fits with Pillar 2.2025-04-0358 minInternational Tax BitesEpisode 81 Familiar Concepts and Pillar 2 - Permanent EstablishmentsIn this episode Grahame and Harriet tackle the thorny issue of the role of the permanent establishment in Pillar 2.
After a recap as to the use of permanents establishments in domestic and treaty law, and some pointless (and edited out) bickering they draw the conclusion that the Pillar 2 definition of Permanent Establishment deviates somewhat from a pure form and will take some time to settle down.
The definition of PE in Pillar 2 is vitally important for helping not only to identify MNEs but also to help with the calculation of the relevant effective tax rates across the globe. of2025-03-2750 min
International Tax BitesEpisode 80 - Familiar concepts and Pillar 2 - Tax ResidenceIn the second episode of their continuing look at Foundational Concepts and how they interact with Pillar 2, Harriet and Grahame think about the concept of Tax Residence and whether it has a place to play in Pillar 2.2025-03-2038 min
International Tax BitesEpisode 79 - Familiar concepts and Pillar 2 - the Tax BaseIn this episode (the first of a short series about foundational concepts and how they interact with Pillar 2) Harriet Brown and Grahame Jackson discuss the impact that Pillar 2 has on the concept of the tax base.
Is the idea of a tax base relevant to Pillar 2? If so how?
They skirt around the future of Pillar 2 and the Trump Administration.2025-03-1445 min
International Tax BitesEpisode 78 - State Aid through the lens of the Apple Case with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.Please note: this episode was recorded some time ago and hence some of the references to days and dates are off.
In this episode Grahame and Harriet discuss the principles of State Aid and how they were applied in 2024's Apple Case. They discuss the underlying issues of state aid and take the listener through the Apple judgment.
Their conclusion is that whilst Apple does not break new ground, it does bring together the principles of State Aid into a single and very important judgment.2025-01-271h 20International Tax BitesEpisode 77 - Rachel Reeves and the £22bn Blackhole - Non doms and tax rises - What on earth is happening in the UK?In this episode Harriet and Grahame talk to James Quarmby of Stephenson Harwood (and Tax LinkedIn Star) about what is happenign in the UK. Rachel Reeves has a a supposed £22bn blackhole to fill and she's sharpening her knife.
We discuss the possibilities of raising more money, whether more money is really actually needed and whether the whole affair amounts to a total failure of the UK political establishment to make tax policy.
Find more about James here
https://www.shlegal.com/en/people/james-quarmby2024-10-1055 min
International Tax BitesEpisode 76: International Tax Cooperation Turf War Part II - The UN Strikes Back! with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.In this episode Harriet and Grahame discuss the recently published Terms of Reference for a United Nations Framework Tax Convention...
What is it?
How far will it go?
Will it succeed?
What will happen if the OECD and the UN don't back down?
All this and more!2024-08-231h 06
International Tax BitesEp 70: Determining the UK tax status of non-UK entities, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode...Grahame and Harriet discuss the approach taken by the UK courts to classifying foreign entities for tax purposes. Especially where the entities exhibit characteristics which do not fit neatly into domestic categories. The case of Memec sets a framework for that approach, Grahame and Harriet examine this and some other countries' approaches.
2024-08-2138 min
International Tax BitesEp 75: Pillar 2 - Too Clever by Half, with Prof. Hans van den Hurk - with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame discuss Pillars 1 and 2 with Professor Hans van den Hurk ...
Why are they so darned complex?
Will they stand the test of time?
Are there alternative methods?
Do many countries have the capacity?
find out more about Hans here
Prof Dr Hans van den Hurk (H.T.P.M.) | Maastricht UniversityHans van den Hurk is an international tax advisor with extensive experience (hhp.law)
2024-08-171h 05
International Tax BitesITB Snax - Episode 8: Non-Dom reforms with Old Square Tax Chambers' Harriet Brown and Hassans', Grahame JacksonIn this ITB Snax episode Harriet Brown discusses the three hot topics of the day in UK tax. Hot on the heels of their election victory the new Labour Government have released policy papers and calls for evidence for reforms of the IHT system, Carried Interest, Non- Dom and VAT on school fees.
This episode is our first reaction to these important proposals... we are both sure we'll be talking about this again!
2024-08-0134 min
International Tax BitesEp 74: The UK-Spain-Gibraltar Tax Treaty - International Tax Bites and Tax Snax with Old Square Tax Chambers' Harriet Brown and Hassans' Grahame JacksonThis special episode is in honour of the publication of "On the principles of Gibraltar Taxation" a book edited by Grahame and available from www.spiramus.com
In this episode Harriet and Grahame discuss the UK/Spain Tax Treaty on Gibraltar. This unique document which was a consequence of Brexit governs the tax interaction between Gibraltar and Spain deserve consideration on its own.2024-07-251h 24International Tax BitesEp 73: The US Green Book - proposals for amendments to GILTIIn this episode Harriet and Grahame (recorded before the recent General Election in the UK) discuss the US Green Book, published in March 2024 which, in its sections on "Reforming International Tax", proposes changes to the GILTI regime.
Will those proposals amount to an aligning between GILTI and the OECD's Pillar 2? Can we see the effect of the global introduction of QDMTTs? What does the Green Book tell us about the direction of travel for US tax policy in a global context?
2024-07-171h 00
International Tax BitesEpisode 72: Skat and the Revenue Rule - with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame discuss the Skatteforvaltningen case in which the Danish tax authorities sought to reclaim wrongly paid tax credits through the English Courts.
This important case set the boundaries of the long standing Revenue Rule in a modern context.2024-06-2645 min
International Tax BitesEp 71: The Webster FATCA Challenge with Old Square Tax Chambers' Harriet Brown and Hassans', Grahame Jackson.In this episode Harriet and Grahame discuss the legal challenges to FATCA and CRS and explain how they feel about the boundaries of what is and what isn't justifiable. FATCA and CRS were introduced in the last decade to mandate exchange of information between banks and foreign tax authorities on the contents of accounts held outside your home jurisdiction. There has long been disquiet amongst professionals about this as an invasion of privacy. A growing number of cases are challenging the legal basis of FATCA and CRS.2024-06-1457 min
International Tax BitesEpisode 69: the Basics of VAT. With Grahame Jackson of Hassans and Harriet Brown of Old Sq Tax ChambIn this episode Grahame and Harriet discuss the basics of Value Added Tax. VAT is one of the most important taxes in the world and one of the least understood. It is paid by almost everyone in a way which is invisible to the end consumer.
This is our first episode on indirect taxes and we look forward to discussing them further in coming episodes.2024-04-2250 min
International Tax BitesEp 68: Designing the Perfect International Tax System: The Final with Grahame Jackson Harriet BrownIn this the final episode of our mini series Designing the Perfect International Tax System Harriet and Grahame review the series and draw lessons from their guests.
Have the designed a system or simply decided its really complicated? They have certainly drawn guests from all aspects of tax thought, philosophers, administrators, economists and more.
Listen to find out in the conclusion of our landmark series "Designing the Perfect International Tax System"2024-03-271h 20
International Tax BitesEp 66: with Paul Eastwood - Designing the Perfect International Tax SystemIn this episode Harriet and Grahame talk about the fate of small jurisdictions in the changing tax landscape, whether they can have a voice and how loud that voice can be. They are joined by Paul Eastwood of KPMG Jersey who draws on his experience in and around the OECD Inclusive Framework to give insights into how small jurisdictions with open economies can participate in the reform of the international tax system.
Paul is the last guest in our miniseries "Designing the Perfect International Tax System", join us for our next episode in which...2024-03-1359 min
International Tax BitesBonus Episode: Budget 2024 - The Abolition of Non-DomIn this bonus episode Harriet and Grahame discuss the abolition of Non-Dom announced on the 6th March by Chancellor Jeremy Hunt, some of the detail around trusts and the proposed FIG regime, and the transitional provisions.
They have some comments for advisers and generally for Non-Doms. In addition they look at the changes to the Transfer of Assets Abroad Regime.2024-03-0741 min
International Tax BitesEp 65: The International Tax Court with Harriet Brown and Grahame Jackson - Designing the perfect International Tax SystemIn this the ninth episode of the mini series "Designing the Perfect International Tax System" Harriet and Grahame discuss the practical options for an international tax court.
What should it be? Who should be able to go to it? Should Harriet be its first chief justice?
Look out for further episodes in this ongoing series. If you are new to the series feel free to go back to the introductory episode.2024-03-0345 min
International Tax BitesEp 64: Peter Dietsch, The International Tax Court - Designing the perfect international tax systemIn this the eighth episode of the mini series "Designing the Perfect International Tax System" Harriet and Grahame speak with Peter Dietsch of the University of Victoria in Canada about the philosophical need for an international tax court.
They have a wide ranging discussion touching on the philosophy of property and the underpinnings of tax as a concept.
Look out for further episodes in this ongoing series. If you are new to the series feel free to go back to the introductory episode.
2024-03-0149 min
International Tax BitesEp 63: Mbakiso Magwape, Engaging with the Process - Designing the Perfect International Tax SystemIn this episode Grahame and Harriet speak to Mbakiso Magwape and discuss the processes around preparing international tax proposals and how developing countries approach the design and implementation of international proposals.
Mbakiso has an extensive CV in private practice, government (he worked as Principle Legal Services Officer - Legislation & Compliance with the Botswana Unified Revenue Service) and is now a post- doctoral fellow with the International Centre for Tax and Development. He brings years of expertise and insight to a process which is regularly criticised as exclusionary and weakened by a lack of inclusion of divergent voices.2024-02-261h 10
International Tax BitesEp 62: Carlos Protto Global Tax and Developing Nations: Part 5 - Designing the perfect international tax systemThis is Part 5 of our series "Designing the Perfect International Taxation System". In this episode
Harriet and Grahame discuss "Global Tax and Developing Nations" with Carlos Protto who is a member of the UN Committee of Experts on Tax Cooperation and is a leading adviser to the Argentine Government on matters of taxation.
Carlos, Harriet and Grahame discuss the role of developing nations in the international tax community and the impact of recent developments on them. The discussion touches on not only the impact of international taxation reform but also the capacity of developing nations to participate...2024-02-1959 min
International Tax BitesEp 61: Sam Mitha, The development of the international tax community. Part 4 - Designing the perfect international tax systemThis is Part 4 of our series "Designing the Perfect International Taxation System". In this episode
Harriet and Grahame discuss "The development of the international tax community" from the perspective of #HMRC with Sam Mitha CBE.
Sam, Harriet and Grahame talk about Sam's experiences in his long career with HMRC and the Inland Revenue where he specialised in international tax policy working with teams that helped develop the UK's controlled foreign company rules and other anti-avoidance provisions. Sam was witness to the shift from tax policy being made in isolation to the comprehensive international cooperation we have today.
Look out...2024-02-161h 19
International Tax BitesEp 60: Thornton Matheson, Global Tax, Capital Importers & Capital Exporters. Part 3 - Designing the perfect international tax systemThis is Part 3 of our series "Designing the Perfect International Taxation System". In this episode
Harriet and Grahame discuss "Global Tax, Capital Importers & Capital Exporters" with Dr. Thornton Matheson who is (amongst many other things) a Technical Assistance Advisor with the International Monetary Fund
Thornton, Harriet and Grahame talk about the economic basis of the international taxation system, how it serves those jurisdictions which import and those which export capital, the radical changes in the post war economy and the pressures that have driven change in the international taxation system.
Look out for further episodes in this on...2024-02-121h 12
International Tax BitesEp 59: Daniel Bunn, Who should participate in an international tax system? Part 2 - Designing the perfect International Tax SystemIn this episode, the second in the miniseries “Designing the Perfect International Taxation System” Harriet and Grahame discuss “Who should participate in the international tax system?” with Daniel Bunn of the Tax Foundation a US not for profit tax think tank which thinks about US and international tax.
In this the second episode in the ongoing mini-series “Designing the Perfect International Tax System” Harriet, Grahame and Daniel discuss the building of the international tax system and the effect of widening the participation in the design of the international tax system from capital exporting countries to include capital i...2024-02-0958 min
Keeping It CivilSeries 2 / Episode 1 - Designing the Perfect International Tax System with International Tax Bites hosts, Grahame Jackson and Harriet Brown.International Tax Bites podcasters, Grahame Jackson, Tax Partner at Hassans and Harriet Brown of Old Square Tax Chambers join Selwyn Figueras, Hassans’ Partner and podcast host of Keeping It Civil, to discuss the launch of the duos recent mini-series, “Designing the Perfect Tax System”.
The 10-part series, topped and tailed with an introduction and a round up, welcomes the great and good of the international tax world, kicking off with Dan Neidle, investigate journalist and ex-Clifford Chance UK Tax Partner.
Over the course of the next few weeks, ITB will be publishing further episodes with the li...2024-02-0837 min
Keeping It CivilKIC Special - Responding to an HMRC Information RequestGuest host, Hassans’ Tax Partner Grahame Jackson, talks to Harriet Brown of Old Square Tax Chambers, London on what Gibraltar entities should do on receiving a request for information from the UK’s HMRC.
Following the introduction of the UK DTA, requests under Section 6A of the Income Tax Act 2010 into Gibraltar are increasingly common. The duo discuss what individual and companies should do, and what they shouldn’t, to avoid potentially hefty penalties.
2024-02-0823 min
International Tax BitesEp 58: Dan Neidle, Do we need an international tax system? Part 1 - Designing the perfect international taxation system:In this the first episode in the miniseries “Designing the Perfect International Tax System” Grahame speaks to Dan Neidle of Tax Policy Associates about whether we need an international tax system and the faults and failings of the current system. Plus, where will all this end and is the coming proposal worth all the fuss?2024-02-0556 min
International Tax BitesEp 57: Introduction - Designing the perfect international taxation system.In this short episode Harriet and Grahame discuss their upcoming mini-series “Designing the Perfect International Tax System” which brings together people from all areas of the tax world, economists, international experts, investigative journalists, tax inspectors and academics. They aim to discuss the ins and outs of how the international tax system is made and what the outcomes may well be in coming years.2024-02-0523 min
International Tax BitesEpisode 56: Professor Rita De La Feria - What is tax for? With Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame are joined by Professor Rita De La Feria of Leeds University.
Professor De La Feria is a world leading Tax Policy expert who frequently speaks on matters of tax to a wider public audience. In this episode the three of us discuss what tax is for, what the best approach to making tax policy is and the weaknesses of the public discourse around tax.2024-01-151h 06
International Tax BitesEpisode 55: Todd Buell - News and views from Brussels, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame talk to Todd Buell of Law 360 about developments in the EU related to tax including #BEFIT #Unshell and all points in between. Will these directives ever see the light of day or is there reform fatigue setting in. Politics will have much influence on this outcome and Todd gives us his feelings about how the future will develop.
This is our last episode of 2023 and we want to thank you all for listening to us for another year. We look forward to seeing you in 2024.2023-12-2150 min
International Tax BitesITB Snax: Episode 7 BVI - Beneficial Ownership RegisterIn this episode of ITB Snax Grahame and Harriet discuss the British Virgin Islands' announcement that they will be suspending their implementation of a publicly available register of beneficial ownership of entities registered in the BVI. This follows from court cases in the EU which ruled such publicly available registers to be be illegal and against the principles of privacy.2023-12-1917 min
International Tax BitesITB SNAX: Christmas Special with Harriet Brown and Grahame Jackson... Blacklisting Santa!In their third Christmas Special edition episode, Grahame and Harriet discuss the shock news of the EU's blacklisting of Santa Claus and the North Pole...2023-12-1113 min
International Tax BitesITB SNAX Episode 5: Expanding UN influence over tax reform, with Harriet Brown and Grahame JacksonIn this short episode Harriet and Grahame discuss developments at the UN as it attempts to seize the initiative when it comes to driving international tax reform.2023-12-0213 min
International Tax BitesEpisode 54: OECD's Corporate Tax Statistics report "Effective Tax Rates of MNEs: New evidence on global low-taxed profit with Hassans Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame talk about some surprising results of the #OECD's Corporate Tax Statistics report "Effective Tax Rates of MNEs: New evidence on global low-taxed profit" which shows that more than half of the "undertaxed" profits in the world arise in nominally high tax jurisdictions.
What creates this gap between statutory rates and actual tax paid? Harriet & Grahame discuss the fact tax systems are more than just headline rates and a gap between statutory rates and actual tax paid may actually be unavoidable.2023-11-3042 min
International Tax BitesEpisode 53: International Tax Information Requests with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Grahame and Harriet explore the procedures and issues around international tax information requests which individuals or institutions may receive from their local tax authorities requesting information for foreign tax authorities.
They discuss what a request looks like, what the limits of that request are and whether a recipient can or is indeed obliged to push back against their local tax authorities.2023-11-2051 min
International Tax BitesEpisode 52: Global Minimum Tax Individuals with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Grahame and Harriet discuss the proposals from the EU Tax Observatory for a global minimum tax to be imposed on individuals. They discuss the design of such a system and possible alternatives2023-11-0643 min
International Tax BitesEpisode 52: Global Minimum Tax Individuals, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Grahame and Harriet discuss the proposals from the EU Tax Observatory for a global minimum tax to be imposed on individuals. They discuss the design of such a system and possible alternatives.2023-11-0648 min
International Tax BitesEpisode 51: SARS and MDR with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame discuss the boundaries of international taxation reporting regimes and the need to make reports under the relevant anti-money laundering regimes. They focus on the interaction of CRS, MDR and POCA. They also give you a round up of their ambitious project "Designing the Perfect International Taxation System", an eight episode epic with globally important guests.2023-10-3147 min
International Tax BitesEpisode 50: International Tax Cooperation Turf War with Grahame Jackson and Harriet BrownIn this the 50th Episode of International Tax Bites, Harriet Brown and Grahame Jackson discuss the recent moves by the UN to take the initiative in the world of International Tax Cooperation which may well amount to the opening shots in a turf war for control of the international tax agenda.
They discuss the failings of the current OECD system, and its strengths, and the level of criticism that the UN is levelling at the OECD. They also share their thoughts on whether the UN proposals have a chance of success.2023-08-211h 09
International Tax BitesITB Snax: Episode 4 - The issue of translations, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame tackle the issue of translations and multilateral international documents, is there an original document or do all official translations carry the same weight?2023-08-1814 min
International Tax BitesITB SNAX: Episode 3 - Retrospective, with Harriet Brown and Grahame JacksonIn anticipation of the 50th Episode of International Tax Bites Harriet and Grahame talk through the last 2 and a half years of tax podcasting, what were their expectations, how long did they think it would last, what are their favourite episodes, and what have they got out of being "leading" international tax podcasters?
What does the future hold and a big thank you to all our listeners. We would especially like to thank; our team in Nic and Cath who have done great things in keeping it together, and to acknowledge the support of...2023-08-1123 min
International Tax BitesEpisode 49: Forseeable Relevance with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet & Grahame discuss the international concept of "Foreseeable Relevance" and how it is a protection for taxpayers and a brake on the ability of tax authorities to request information from each other.
This important concept is embedded in nearly all the various information exchange regimes across the globe and an understanding of it is vital for the international tax adviser. Is it a uniform concept, is it an effective protection for taxpayers?2023-08-0451 min
International Tax BitesITB SNAX: Episode 2 - Quad Island Forum with Harriet Brown and Grahame JacksonIn this our second ITB Snax, Grahame and Harriet discuss the Quad Island Forum, a cooperation forum for #Jersey, #Guernsey, #IsleofMan and #Gibraltar to pool expertise and best practice in financial crime and investigating serious tax fraud.2023-07-2814 min
International Tax BitesITB SNAX: Episode 1 - EU Corporate Own Resources Proposal with Harriet Brown and Grahame JacksonIn the first of our bitesize episodes ITB Snax...Harriet and Grahame discuss the EU Corporate Own Resources Proposal, how it will help the EU to fund itself and who is going to pay for it.2023-07-2108 min
International Tax BitesEpisode 48: Todd Buell, Law 360 Journalist on EU Tax PolicyIn this episode a returning Harriet and Grahame talk to Todd Buell of Law 360 (a legal news service aimed at professionals) about EU tax policy, in particular, BEFIT, SAFE, Pillars 1 & 2 and the Unshell Directive... the politics around them, overreach and whether the world is starting to suffer from reform fatigue.
You can find more out about Todd here
And follow him on Twitter at @ToddBuell
Law360 is a subscription legal news service for professionals of all kinds.
*****Correction***** in our discussion of Pillar 1 we stated that taxing rights...2023-07-131h 11
International Tax BitesEpisode 47: Dr. Peter Dietsch and the Philosophy of TaxIn this episode Grahame speaks to Dr Peter Dietsch of University of Victoria in Canada, they discuss what is tax justice, Peter's work Catching Capital, and the current wave of international tax reforms from a philosophy of tax perspective.
'Catching Capital' is available from the Oxford University Press here
https://global.oup.com/academic/product/catching-capital-9780190251512?cc=gi&lang=en&
and you can find out more about Peter's work here.
Peter Dietsch - University of Victoria (uvic.ca)
2023-07-1156 min
International Tax BitesEpisode 46: Central Management and Control Test with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn their first ever face to face recording, Grahame and Harriet are talking about the "central management and control" test, which is one of the ways that a corporate body can find itself resident in the UK for tax purposes.
You can find out more about Grahame, here: Grahame Jackson
You can find out more about Harriet, here: Harriet Brown2023-06-1638 min
International Tax BitesEpisode 45: Section 86 TCGA - Taxing Capital Gains and Offshore Trusts. With Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame discuss the provisions of sections 86 and 87 of the Taxation of Chargeable Gains Act. This powerful piece of anti-avoidance is relevant to anyone who deals with trusts outside the United Kingdom, especially trustees, beneficiaries and settlors.
You can find out more about Grahame, here: Grahame Jackson
You can find out more about Harriet, here: Harriet Brown2023-06-0858 minInternational Tax BitesEpisode 44 New Zealand... Pillar 2 and The status of OECD CommentaryIn this episode Harriet and Grahame discuss the recently published New Zealand Bill for the Pillar 2 Globe Rules. They discuss whether incorporating guidance issued by the OECD into law without any oversight is problematic and the status of guidance in general.2023-05-3035 min
International Tax BitesEpisode 43 - The boundaries of deductible expense....In recent weeks there have been media reports in the UK of an Only Fans creator claiming a deductible expense for career enhancing cosmetic surgery. In this cross over episode with Tax Snax Harriet and Grahame explore the boundaries of what is allowable as a deductible expect in terms of the phrase "wholly and exclusively incurred".2023-04-1422 min
International Tax BitesEpisode 42: International Tax Concepts for Bodies Corporate - with Hassans' Grahame Jackson & Old Square Tax Chambers' Harriet BrownInternational Tax Bites and TaxSnax join forces to discuss important International Tax concepts for Bodies Corporate2023-04-0541 min
International Tax BitesSeries 6 / Episode 6: The CIOT - what is it and what does it do? With Hassans' Grahame Jackson & Old Square Tax Chambers' Harriet BrownIn this episode, in the absence of Grahame, Harriet speaks to Susan Ball, President of the Chartered Institute of Taxation and RSM and, John Cullinane Public Policy Director of the CIOT https://www.tax.org.uk/about-us/spokespeople.
They discuss what the aims of the CIOT are, how it helps the profession and encourages education and continuing training amongst tax advisors. They touch on the qualifications the CIOT sponsors and its role in national and international policy making.2023-01-1644 min
International Tax BitesSeries 6 / Episode 5: The UK Notification of Uncertain Tax Treatment Regime (NUTT) with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownThe UK Notification of Uncertain Tax Treatment Regime. In this episode Harriet and Grahame discuss the new Notification of Uncertain Tax Treatment Regime (or NUTT). They also muse on the status of guidance and the privileging of HMRC's position on disputed tax treatments. Happy New Year to all our listeners.2023-01-0341 min
International Tax BitesSeries 6 / Episode 4: Santa & Pillar 2 - is this the end of Demi God gift giving?In this episode Harriet and Grahame discuss the impact of Pillar 2 (the OECD's global minimum tax rate proposal) . After explaining the basics of Pillar 2 they analyse whether Santa will be caught by the net of Pillar 2 and whether this will be a breach of international law surrounding Santa's special status under Article 4 of the Ho-Ho-Ho ECD's Multilateral Convention on Gift Giving Demi Gods.
Listen in for these and other terrible Christmas themed puns. And Harriet surprises Grahame with an on the spot quiz!
Merry Christmas everyone.2022-12-2228 min
International Tax BitesSeries 6 / Episode 3: The EU Code of Conduct Group and changes to blacklisting criteria, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame discuss the EU Blacklist, and the 8th November 2022 changes to the backlisting criteria. The EU Code of Conduct Group and its black and greylists are the most effective international listing regime for taxation systems which are considered harmful by the EU. Inclusion on the blacklist can have quite severe economic and reputational consequences for some jurisdictions. Harriet and Grahame discuss whether the listing system is the most equitable approach and what if any weaknesses it may have in its current form.2022-12-0547 min
International Tax BitesSeries 6 / Episode 2: Autumn Statement 2022 Special with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet returns to discuss with Grahame the Autumn Statement of 17th November 2022. In terms of tax what has the Chancellor done, how much will it raise and will it work? 2022-11-1829 min
International Tax BitesSeries 6 / Episode 1:Pillar 2 - what is it and what's going on? Ft Leonard WagenaarIn the absence of Harriet who was busy with her day job, Grahame spoke to Leonard Wagenaar, an expert on international tax developments over the last few years, about the continuing efforts to implement Pillar 2 or the Global Minimum Tax Rate.
They discussed in general terms what Pillar 2 is the effect of the Domestic Top Up Tax, Income Inclusion Rule and the Untaxed Payment Rule rules and how they interlock. They then went on to discuss the political manoeuvring around implementation; the problems the United States has in getting to the starting gate and the EU's internal difficulties with the v...2022-11-1040 min
International Tax BitesSeries 5 / Episode 6 ft Dominic Sandbrook: The Making of the Modern Tax Base Part TwoIn this episode Harriet and Grahame are joined by internationally renowned historian Dominic Sandbrook of the Rest is History podcast to discuss the making of the modern British tax base.
In part two they cover the period from mid 1960s to 1990 discussing the Great Inflation, the Winter of Discontent and the Thatcher Revolution along with the recent developments in UK, the impacts these events had on the tax policy and structure of the tax system of the UK, and finally does politics even really have an impact.
Dominic Sandbrook is a leading historian and author of a series of books...2022-10-121h 07
International Tax BitesSeries 5 / Episode 6 ft Dominic Sandbrook: The Making of the Modern Tax Base, Part OneIn this episode Harriet and Grahame are joined by internationally renowned historian Dominic Sandbrook of the Rest is History podcast to discuss the making of the modern British tax base.
In part one they cover the period from 1945 to the mid-1960s, discussing the birth of the welfare state, the socialisation of the economy under Labour, the post war consensus, and the impacts these events had on the tax policy and structure of the tax system of the UK.
Dominic Sandbrook is a leading historian and author of a series of books on post-war Britain including Never Had it So...2022-10-1144 min
International Tax BitesSeries 5 Episode 5: ft Prof Johann Hattingh Anti Avoidance and tax in AfricaIn this episode Harriet and Grahame speak Professor Johann Hattingh of University of Cape Town. Using the famous tax case Duke of Westminster they discuss the development of tax law in English speaking Africa, in particular, Kenya, Tanzania, Nigeria and South Africa. They also look to the future with thoughts about the role of the UN, the OECD and the African Tax Administrators Forum (ATAF) and the demands being made on revenue authorities in Africa.
We are very proud to welcome such a well respected guest and have been very fortunate this series. You can learn more about Professor Hattingh h...2022-10-0344 min
International Tax BitesSeries 5 / Episode 4: Commonly used words and phrases in International Tax, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.In this episode Harriet and Grahame discuss some of the more commonly phrases in International Tax such as "avoidance" "arm's length" "purpose" and "main purpose" amongst other things. They also discuss the correct location of the apostrophe in "arm's length".2022-09-1345 min
International Tax BitesSeries 5 / Episode 3: Transfer of Assets Abroad, Part 2 with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this the second episode of the Transfer of Assets Abroad Regime discussion Harriet and Grahame discuss the various types of motive defence available to taxpayers. They also compare TOAA to its related but very different capital gains tax charge s86 TCGA.2022-09-0752 minInternational Tax BitesSeries 5 / Episode 2: Transfer of Assets Abroad with Hassans’ Grahame Jackson and Old Square Tax Chambers' Harriet Brown.In this episode Harriet and Grahame tackle the Transfer of Assets Abroad regime which is one of the most effective tools in the anti-avoidance tool kit of the HMRC. They discuss the three charges to tax contained in TOAA, the definition of Associated Operations and the general principles underlying the regime. They will complete the topic in the upcoming Part 2 of the Transfer of Assets Abroad Regime.2022-08-3145 minInternational Tax BitesSeries 5 / Episode 1:ft Prof Philip Baker QC State Aid with Grahame Jackson and Harriet BrownThe topic of discussion in this episode is the EU State Aid regime and its post Brexit descendant. Grahame and Harriet speak with Professor Philip Baker QC, unrivalled expert in all things tax. Professor Baker teaches at Oxford University and is a barrister with Field Court Tax Chambers. He is one of the most respected in his field globally.2022-08-221h 10International Tax BitesCompetition Winners!In this short episode Grahame and Harriet announce the winners of their prize draw for an International Tax Bites mug! 2022-08-0802 min
International Tax BitesSeries 4 / Episode 6: Transfer pricing with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriett BrownThe topic of discussion in this episode is the basics of transfer pricing, what are the transfer pricing rules for, what do they try and tackle and what are the approved methods of calculating transfer prices. This is a basic introduction to a very complex topic and we hope that we have tackled it well.
Most importantly in this episode Harriet and Grahame run a competition for listeners to win an International Tax Bites mug! the question is "What does 'OECD' stand for?" answers by email with your postal address to internationaltaxbites@gmail.com.
2022-07-071h 02
International Tax BitesSeries 4 / Episode 5: The OECD's proposals to extend the Common Reporting Standard to cover Crypto assets and exchanges.In this episode Harriet Brown and Grahame Jackson discuss the OECD's proposals to extend the Common Reporting Standard to cover Crypto assets and exchanges. The proposed rules can be found at https://www.oecd.org/tax/exchange-of-tax-information/public-consultation-document-crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard.pdf
Harriet and Grahame discuss which entities will be in scope, what assets will be reportable, and what will be reported on the individuals involved, plus the timeline for implementation.
If you are operating a crypto exchange, or believe you will be obliged to report under the Crypto Asset Reporting Regime, feel free to contact us on...2022-06-2945 min
International Tax BitesSeries 4 / Episode 4: The boundaries of Tax Reporting and Human Rights featuring Filippo Noseda, Mishcon de ReyaIn our 25th episode, Harriet Brown and Grahame Jackson spent their morning chatting with the brilliant Filippo Noseda from Mischon de Reya about the boundaries of automatic exchange of information and whether the balance between citizen and state have shifted too far in favour of the state.
2022-06-2248 min
International Tax BitesSeries 4 / Episode 3: International Recognition of Trusts with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode, Harriet and Grahame talk through the Hague Convention related to the International Recognition of Trusts. Which country's laws apply to a trust can have tax consequences but it's generally important as well when trusts deal across borders and may well be subject to consideration by the courts.2022-06-2037 min
International Tax BitesSeries 4 / Episode 2: Statutory Residence Test with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.In this episode Harriet and Grahame talk about the UK's statutory residence test. When it was introduced in 2013 the SRT was hailed as simplifying what was previously a minefield of uncertainty and a common law test. In fact it is one of the most complex residence tests Harriet and Grahame have ever come across.2022-05-3052 min
International Tax BitesSeries 4 / Episode 1: Can tax authorities collect each other's tax? The Revenue RuleIn this episode Harriet and Grahame discuss the rules surrounding whether or not countries can recover tax debts through foreign courts. From the original rule in the Government of India case (Government of India v Taylor [1955] AC 491) known as the Revenue Rule through recent case law in SKAT (Skatteforvaltningen v Solo Capital Partners Llp [2022] EWCA Civ 234 (25 February 2022)) and discussing the EU and global agreements which mandate mutual assistance on taxing authorities, Harriet and Grahame discuss the development of cross border assistance in tax collection2022-05-2034 min
International Tax BitesSeries 3 Bonus episode: Russia... CRS... and the international community with Hassans' Grahame Jackson and Old Square Tax Chambers', Harriet BrownIn this episode Harriet and Grahame discuss the recent suspension by UK of its tax information exchange relationships with Russia under CRS and Country by Country reporting. They talk about what this could mean for financial institutions. Later on they consider whether the approach of seeking 100% global participation in CRS and other tax exchange regimes is correct especially as professionals may be mandated to collect information that will assist the collecting of tax by countries which behave in unacceptable ways.2022-03-2119 min
SorainenENG | Tax Stories Podcast – Episode 17 – Harriet Brown (UK barrister) and Grahame Jackson (Hassans)Tax Stories Podcast – Episode 17– Harriet Brown and Grahame Jackson.Harriet Brown and Grahame Jackson are authors of a podcast International Tax Bites that explains different tax concepts. They both in September 2021 released a book “A Practitioner’s Guide to International Tax Information Exchange Regimes”, published by www.spiramus.com. Harriet practices tax in the UK, but Grahame – in Gibraltar. We discussed their careers, the podcast, the book and the global tax issues at large.https://tax-stories.simplecast.com/episodes/harriet-brown-uk-barrister-and-grahame-jackson-hassans-on-information-exchange-and-tax-podcasts-Q_f_wX_4Subscribe here if you would like to receive lega...2022-02-0759 min
International Tax BitesSeries 3 / Episode 6: Crypto assets featuring Tarik Chebib, Currency.com, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this long anticipated episode of International Tax Bites Harriet Brown and Grahame Jackson talk to Tarik Chebib of Currency.com . They discuss what a crypto asset is (from Bitcoin to NFTs), where it is located, the ways in which it can make you money and the tax consequences of that. Tarik provides technical back up as the guys discuss this conceptually difficult asset class.
Thank you to Currency.com a crypto exchange that provides crypto trading from a regulated platform for their help in producing this episode.
The OECD report that Harriet mentions can...2022-01-2449 min
International Tax BitesSeries 3 / Episode 5: Featuring Sven Steinmo & John D’Attoma with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.In Episode 5 of Series 3 Grahame and Harriet are proud to talk to Sven Steinmo and John D’Attoma. Sven is a Professor at University of Colorado Boulder and a leading political scientist who has written several books over the last thirty years and has made significant contributions to the field of social science. John is a research social scientist with the Internal Revenue Service and has previously taught at the University of Exeter Business School and the European University Institute.
In this episode Harriet, Grahame, John and Sven discuss John and Sven’s new book Willing to Pay from Oxford Univ...2022-01-171h 10
International Tax BitesSeries 3 / Episode 4: Economic Substance with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this fourth episode of the latest series, Grahame and Harriet discuss the economic substance tests which have been introduced by the crown dependencies and overseas territories of the UK and other jurisdictions in recent years. These important provisions are having a major impact on low tax jurisdictions and are an important consideration for those managing or establishing entities in the relevant jurisdictions.
"A Practitioner's Guide to International Automatic Tax Information Exchange Regimes" which will be published on 1st September 2021 and is available to pre-order here: https://spiramus.com/automatic-exchange-of-information2021-12-2153 min
International Tax BitesSeries 3 / Christmas Special: Santa - tax evader or tax compliant? With Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.In this episode, Grahame and Harriet discuss the very important issue of whether Santa is a tax evader or tax compliant.
We wish everyone a very merry Christmas and happy New Year!2021-12-2015 min
International Tax BitesSeries 3 / Episode 3: Tax Avoidance with Hassans' Grahame Jackson and Old Square Tax Chambers', Harriet Brown.In this episode Harriet and Grahame discuss the concept of tax avoidance, what it is, what it is not and whether it is allowed. They discuss the differences in approach to defining tax avoidance in the EU and UK and discuss what distinguishes tax avoidance from other types of tax behaviour.
"A Practitioner's Guide to International Automatic Tax Information Exchange Regimes" which will be published on 1st September 2021 and is available to pre-order here: https://spiramus.com/automatic-exchange-of-information2021-12-1333 min
International Tax BitesSeries 3 / Episode 2: Hybrid Mismatches with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.In this episode Harriet and Grahame discuss what is meant by the term Hybrid Mismatch, how they arise and how anti-avoidance measures are used to stop taxpayers taking advantage of them.
Grahame and Harriet's book, "A Practitioner's Guide to International Automatic Tax Information Exchange Regimes" is available to purchase here: https://spiramus.com/automatic-exchange-of-information2021-12-0630 min
International Tax BitesSeries 3 / Episode 1: Different ways to be a Tax Professional with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this episode Harriet and Grahame have the pleasure of discussing the different types of tax professionals with Jack Bonehill of the Tax Professionals Podcast (www.thetaxprofessionalspodcast.com) . They discuss the different roles of tax barrister, tax solicitor and chartered tax advisor and the differing routes to qualification.2021-12-0644 min
International Tax BitesSeries 3 / Episode 2: Hybrid Mismatches with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.In this episode, Harriet and Grahame discuss what is meant by the term Hybrid Mismatch, how they arise and how anti-avoidance measures are used to stop taxpayers taking advantage of them.
Grahame and Harriet's book, 'A Practitioner's Guide to International Automatic Tax Information Exchange Regimes' is available here: https://spiramus.com/automatic-exchange-of-information 2021-12-0630 min
International Tax BitesDAC7 Webinar InviteOn Friday 29th October (1pm BST, 2pm CEST, 3pm GST, and 7am EDT) Harriet and Grahame will be giving a Webinar on the provisions of DAC7, the latest iteration of the Directive on Administrative Cooperation. The aim of #DAC7 is to extend #CRS style reporting to digital platforms. It will have an impact on both EU and non-EU based digital platforms.
If you wish to attend please email internationaltaxbites@gmail.com
We look forward to seeing you!
2021-10-2301 min
International Tax BitesBonus Episode: News Line Tax! OECD Global Minimum Tax, EU Blacklist and the Pandora PapersIn this bonus episode Harriet Brown of Old Sq Tax Chambers and Grahame Jackson of Hassans International Law Firm in Gibraltar discuss recent news in the tax world including the recent announcements about the OECD Pillar 1 and Pillar 2 proposals for a global minimum tax rate from the meetings of the Inclusive Forum, the recent updates to the EU List of Non-Cooperative Jurisdictions and the release of the Pandora Papers.
OECD Pillar 1 and 2 discussion at 2 minutes 12 seconds
EU Blacklist discussion: 29 minutes 21 seconds
Pandora Papers 44 minutes 27 seconds
Find out more about Harriet and...2021-10-1858 min
Tax Stories: Life, Business & TaxEp.17 Harriet Brown & Grahame Jackson on info exchange and tax podcastsHarriet Brown and Grahame Jackson are authors of a podcast International Tax Bites that explains different tax concepts. They both in September 2021 released a book "A Practitioner's Guide to International Tax Information Exchange Regimes", published in September 2021 by www.spiramus.com. Harriet practices tax in the UK, but Grahame – in Gibraltar. We discussed their careers, the podcast, the book and the global tax issues at large. GibraltarWe start with discovering Hassans International Law Firm where Grahame is a partner. Having the population in Gibraltar of 28,000 people the size of the firm (300 people) is surprisingly lar...2021-09-3059 min
International Tax BitesSeries 2 / Episode 6: Automatic Exchange Regimes with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet BrownIn this final episode of series 2, Grahame and Harriet discuss the major automatic exchange of tax information regimes. This is also the topic of their upcoming book, "A Practitioner's Guide to International Automatic Tax Information Exchange Regimes" which will be published on 1st September 2021 and is available to pre-order here: https://spiramus.com/automatic-exchange-of-information
This episode is brought to you in collaboration with Spiramus Press, publishers of Harriet and Grahame's book. 2021-08-271h 03
International Tax BitesSeries 2 / Episode 5: General Anti Abuse Rules with Hassans' Grahame Jackson and Old Square Chambers' Harriet Brown.In this week's episode Harriet and Grahame discuss General Anti Abuse Rules or GARRs. They look at the UK GARR and the EU ATAD GAAR and then review the differing types of GARR in this context, looking at the differing features. They review examples of GARRs in the low tax world and how they operate and, which of the EU and UK GAAR they most resemble.
This episode is brought to you in collaboration with Spiramus Press, publishers of Harriet and Grahame's book "A Practitioner's Guide to International Automatic Tax Information Exchange Regimes" which will be published...2021-08-1742 min
International Tax BitesSeries 2 / Episode 4: The Badges of Trade with Hassans' Grahame Jackson & Old Square Chambers' Harriet Brown.In this episode Harriet and Grahame discuss the common law badges of trade test. Why is it important to understand which income arises from trade and which income doesn't? The Badges of Trade are related to but distinct from the distinction between income and capital and this week they analyse where the test came from and what its characteristics are.2021-07-3040 min
International Tax BitesSeries 2 / Episode 3: Income, Capital or Capital Gains with Hassans' Grahame Jackson and Old Square Chambers' Harriet Brown.In this episode of International Tax Bites, Grahame Jackson and Harriet Brown discuss the difference between income, capital and capital gains and why the distinction matters, particularly if you are in a jurisdiction which charges tax on each at different rates and/or different times. 2021-07-1235 min
International Tax BitesSeries 2 / Episode 2 - Malta's Greylisting with Grahame Jackson, Tax Partner at Hassans and Harriet Brown, Old Square Tax Chambers.International Tax Bites explores concepts and issues in international taxation. In this episode the duo, Harriet Brown and Grahame Jackson, go off piste and explore what the greylisting of Malta means, who the #FATF are and what those who deal with #Malta can expect to see in light of this development.
2021-07-0531 min
International Tax BitesSeries 2 / Episode 1 - Global Tax Rate with Grahame Jackson at Hassans & Harriet Brown at Old Square ChambersIn the first episode of series 2 of International Tax Bites, Grahame and Harriet grapple with the recent G7 announcement that was made regarding a global minimum tax rate and a change in the basis of International Taxation.
What does it say? Does it deliver on its promise? How will it work? Contact us on internationaltaxbites@gmail.com2021-06-2431 min
International Tax BitesEpisode 6 - Source of Income with Grahame Jackson at Hassans and Harriet Brown of Old Square Tax Chambers.International Tax Bites explores concepts and issues in international taxation. In this last episode in Series 1 Grahame and Harriet discuss sources of income / gains, how to identify source and how technology is impacting on international taxation in general.
See you in the Summer for Series 2.
2021-03-2634 min
International Tax BitesEpisode 5 - Double Taxation with Grahame Jackson at Hassans and Harriet Brown of Old Square Tax Chambers.International Tax Bites explores concepts and issues in international taxation. In this episode Grahame and Harriet discuss double taxation.
How it arises, the methods by which it is resolved, and some practical issues. They look at some examples of Double Tax Treaties and consider their operation.2021-03-1923 min
International Tax BitesEpisode 4 - Permanent Establishment with Grahame Jackson at Hassans and Harriet Brown of Old Square Tax Chambers.International Tax Bites explores concepts and issues in international taxation. In this episode Grahame and Harriet discuss the complexities of permanent establishment, what it is, how it works and is there a cream for it! 2021-03-1234 min
International Tax BitesEpisode 3 - Domicile with Grahame Jackson at Hassans and Harriet Brown of Old Square Tax Chambers.International Tax Bites explores concepts and issues in international taxation. In this episode Grahame and Harriet discuss the complexities of establishing domicile.2021-03-0624 min
International Tax BitesEpisode 2 - Personal Tax Residence with Grahame Jackson, Tax Partner at Hassans and Harriet Brown, Old Square Tax ChambersInternational Tax Bites explores concepts and issues in international taxation. In this episode Grahame and Harriet discuss personal tax residence including how to determine tax residency and relevant treaties.2021-02-2633 min
International Tax BitesEpisode 1 - Corporate Tax Residence with Grahame Jackson, Tax Partner at Hassans and Harriet Brown, Old Square Tax ChambersWelcome to a new podcast series by Hassans’ Partner Grahame Jackson and Harriet Brown of Old Square Tax Chambers.
International Tax Bites explores concepts and issues in international taxation. In this first episode Grahame and Harriet discuss Corporate Tax Residence.2021-02-2523 min