Shows
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 20
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
CommsDay Live30 Years of CommsDay; An interview with founder Grahame Lynch part 2Welcome to the second episode of our special series celebrating the 30th anniversary of Communications Day. Hosted by former Comms Day editor Tim Marshall and featuring Grahame Lynch, the founder and publisher of Comms Day, this episode dives deep into the major themes and events that have shaped the telecommunications sector over the past three decades.
We explore the evolution of Telstra, the development of universal high-speed broadband, and the ongoing saga of the NBN. Grahame shares his personal insights on the twists and turns that have defined the industry, reflecting on technological shifts, policy responses, and...2024-08-081h 25
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 24CommsDay Live30 Years of CommsDay; An interview with founder Grahame Lynch part 1Welcome to CommsDayLive with Tim Marshall, former editor of CommsDay and now a communications and corporate affairs consultant. This is the first episode in a special series celebrating the 30-year journey of Communications Day, the publication often referred to as the Bible of Australian telecommunications.
In this episode, Tim sits down with the man behind it all, Grahame Lynch, the founder, publisher, editor, commentator, event producer, podcast host, and more. Grahame shares the story of CommsDay's inception, its early days, and its incredible journey of charting the perpetual evolution of the telecommunications industry.
Discover the...2024-07-221h 10
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 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 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 minCommsDay Live#110 AWS' chief telco technologist Ishwar Parulkar on AI, APIs, cloud RAN and moreThis week Grahame Lynch chats with AWS chief technologist, telco Ishwar Parulkar from California on his predictions for 2024 including increased use of AI by telcos, more comfort with SaaS and APIs, and a renewed move to cloud RANs. Grahame also chats with CommsDay managing editor Rohan Pearce about the news of the week
2024-02-0226 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: 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 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 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 minCommsDay Live#87 The Optus data breach and what’s happening at RibbonThis week Grahame Lynch talks about the Optus data breach and we hear from Optus CEO Kelly Bayer Rosmarin, communications minister Michelle Rowland and treasurer Jim Chalmers.
Grahame also talks with the visiting SVP from Ribbon Communications, David Hiscock.
2022-10-0737 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 min
International 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 10
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 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
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 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
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
Dr. Frightful Presents: A PodcastEpisode 13: Elysium FieldsGood Evening My Dear Listeners....Jenny is on her way to her best friend's wedding. Little does she know, sometimes life puts us on a different road and sometimes that road is a DEAD ENDScary-o-Meter:2 Ghosts out of 5-------------------------------------Elysium Fields was Written by Jennica GrienkeDirected and Edited by Grahame KentFeaturing the voice talents of Danielle Roy as Jenny RandallGrahame Kent as Officer LeRoy Jr. and Mr. Hayden Andrew Taylor as CharlieJohanna Arnott as Pe...2021-02-1127 min
Dr. Frightful Presents: A PodcastEpisode 12: SlobberknockerGood Evening My Dear Listeners....Welcome to Wrasslefest! Will Vic The Viper Defend his championship? Or will The Gravedigger win with his zombie hoard? Just be careful where you get your occult embellishments.....Scary-o-Meter:1.5 Ghosts out of 5-------------------------------------Content Warning: Gore-------------------------------------Slobberknocker was Written by James AvramenkoDirected and Edited by Grahame KentFeaturing the voice talents of James Avramenko as Billy Bob and Vic The ViperLuke Pennock as The Duke and Ornery Orville2021-01-2025 min
Dr. Frightful Presents: A PodcastEpisode 11: Can I Come In Though?Good Evening My Dear Listeners....There is a Vampiric Plague sweeping the nation. Just remember the old saying: A Vampire Can Only Come In If They Are Invited.....Scary-o-Meter:1.5 Ghosts out of 5-------------------------------------Can I Come In Though was Written by Grahame KentDirected and Edited by Grahame KentFeaturing the voice talents of Danielle Roy as Hilda HendersonKatelyn Polischuk as Dr. Beth Acula, MDLuke Pennock as KeithJennica Grienke as JudyJames Avramenko as Sam the V...2021-01-0621 min
Dr. Frightful Presents: A PodcastEpisode 10: Merry Frightsmas!Good Evening My Dear Listeners....Its the eve of the scariest yuletide festival of the year. Are you ready for Dr. Frightful to visit you?Scary-o-Meter:0 Festive Ghosts out of 5-------------------------------------Merry Frightsmas! was Written by Jennica Grienke and James AvramenkoDirected and edited by Grahame KentFeaturing the voice talents of :Grahame Kent as The Burl Ives Stand InJames Avramenko as Grandpa Andrew Taylor as JimmyJennica Grienke as BirdieAnd Grahame Kent as Dr. Frightful....2020-12-2410 min
Dr. Frightful Presents: A PodcastEpisode 9: Alien Ant FarmGood Evening My Dear Listeners....How well do we know our parents? Are they even the "people" we know them to be?Scary-o-Meter:2.5 Ghosts out of 5-------------------------------------Alien Ant Farm was Written by Andrew TaylorDirected by Grahame KentEdited by Johanna Arnott with Grahame Kent Featuring the voice talents of Johanna Arnott as AbbyDanielle Roy as Myra and Ad WomanGrahame Kent as Ad DoctorKatelyn Polischuk as the Interviewer and The VoiceAndrew Taylor as Fr...2020-12-1629 min
Dr. Frightful Presents: A PodcastEpisode 8: The Doctor Is In and An Evening With Dr. FrightfulGood Evening My Dear Listeners....Come with me now as we listen to the failed pilot of a medical drama I made in the 90's as well as an exclusive interview about my mysterious past.......Scary-o-Meter:1 Ghosts out of 5-------------------------------------The Doctor Is In was Written by Andrew TaylorAn Evening With Dr. Frightful was Written by Andrew Taylor and Grahame KentDirected by Andrew TaylorEdited by Grahame Kent Featuring the voice talents of Johanna Arnott as Nurse ConcernDa...2020-12-0328 min
Dr. Frightful Presents: A PodcastEpisode 7: 51 Pumpkin Patch LaneGood Evening My Dear Listeners....Get ready for a Close Encounter of the 6th kind. Don't look that up, it is a spoiler.Bob Tucker is in a heap of trouble as he hangs halfway between the ground and a tuna can type space ship.****************************************Content Warning: Adult Themes****************************************Scary-o-Meter:1 Ghosts out of 5-------------------------------------51 Pumpkin Patch Lane was Written by Danielle RoyDirected by Grahame KentEdited by Grahame Kent and Phoebe TaFeaturing the voice t...2020-11-1823 min
Dr. Frightful Presents: A PodcastEpisode 6: WavesGood Evening My Dear Listeners....Is there any job more lonely than a Lighthouse Keeper? Left alone on a forgotten rock surrounded by the sea in the dead of a long winter. At least you have a corpse to keep you company.********************Language Warning********************Scary-o-Meter:3 Ghosts out of 5------------------------------------------------------Waves was Written, Directed and Edited by Grahame KentFeaturing the voice talents of Danielle Roy as HowellGrahame Kent as McGinnis...2020-11-0421 min
Dr. Frightful Presents: A PodcastEpisode 4: Dead LanguagesGood Evening My Dear Listeners....We are gonna need an old priest, a young priest and a whole lotta towels. What would you do if a sweet innocent child was possessed by a demon? Who ya gonna call? An Exorcist probably. Scary-o-Meter:2 Ghosts out of 5-------------------------------------Dead Languages was Written by James AvramenkoDirected and Edited by Grahame KentFeaturing the voice talents of Danielle Roy as The Concerned MotherGrahame Kent as Father Rudolph2020-10-2823 min
Dr. Frightful Presents: A PodcastEpisode 3: Make It! Episode 75; Exiting the Clone ZoneGood Evening My Dear Listeners....Today on Make It! we will learn how to ethically dispose of the clone of ourselves we made last week! This method is only safe for clones made from our verified recipe and does not include naturally occurring doppelgangers or shape-shifters.****************************************Content Warning: Domestic Violence****************************************Scary-o-Meter:3.5 Ghosts out of 5-------------------------------------Make It Episode 75; Exiting The Clone Zone was Written by Katelyn PolischukDirected and Edited by Grahame KentFeaturing the voice talents of 2020-10-2120 min
Dr. Frightful Presents: A PodcastEpisode 2: Sask-WatchGood Evening My Dear Listeners....Come with us now and hear the tale of Sir Barnaby Sooths and the elusive Soothsbeast....Scary-o-Meter:1 Ghosts out of 5-------------------------------------Sask Watch was Written and Directed by Grahame KentEdited by Phoebe Ta and Grahame KentFeaturing the Voice Talents of:Andrew Taylor as Sir Barnaby SoothsDanielle Roy as The BEASTand Grahame Kent as Dr. Frightful2020-10-1428 min
Dr. Frightful Presents: A PodcastEpisode 1: Well, Well, WellGood Evening My Dear Listeners....What would you do if you found a well hidden in the center of your living room?Scary-o-Meter:4 Ghosts out of 5-------------------------------------Written by Johanna ArnottEdited and Directed by: Grahame KentFeaturing the Voice Talents of:Jennica Grienke as CarmenKatelyn Polischuk as Paulineand Grahame Kent as Dr. FrightfulDr. Frightful's Theme and Credits music performed by...2020-10-0719 min
Music Talk : Music Industry Interviews, Advice and tips for DJs & Producers061 - The 10,000 streams podcast - Motivation & Goals for 2020Welcome to BOOST Podcast, with me, Grahame Farmer.
For the past 2 years, I’ve been giving out Tips to DJs via my Instagram @grahamefarmer since then we set up our BOOST 1to1 Coaching service - which is currently going through our first intake in 3 months, we are doing BOOST Breakfasts at the Electronic Sound Summit in Liverpool on 28th February for my northern crew.
Come out check out that Conference
In April, Brighton Music Conference returns again, it was mega last year - and i hosted my very first BOOST breakfast - which is...2020-01-2808 minMusic Talk : Music Industry Interviews, Advice and tips for DJs & Producers043 - Peak Performance & Wellbeing with Dan GayleDan Gayle grew up partly in London and partly in Suffolk. He’s been running his own business as a coach since 2012, which was part-time initially, then left a 10-year career in finance behind to pursue it fully at the end of 2014. What started out as “Life Coaching”, his services have evolved to become Peak Performance & Wellbeing Coaching, as he is both fascinated by AND passionate about maximising human potential.
He is the creator of The 6P’s Peak Performance & Wellbeing Coaching Framework, which brings together decades of experience from multiple industries such as business, coaching, personal developmen...2019-10-1056 minMusic Talk : Music Industry Interviews, Advice and tips for DJs & Producers036 - How to get more PLAYS on MixcloudWelcome to the BOOST podcast with me, Grahame Farmer.
If this is the first time joining me on the podcast, it all started as part of 100 day challenge which was a need because i was procrastinating for 14 months to start one.
For the past 18 months previously, I’ve been giving out Tips to DJs via my Instagram @grahamefarmer since then we set up our BOOST 1to1 Coaching service, we’ve had BOOST breakfasts at IMS and BMC. We have a BOOST weapons release series for artists on my 1to1 Coaching and now this BOOST podcast.
2019-09-2008 minMusic Talk : Music Industry Interviews, Advice and tips for DJs & Producers032 - Juany Bravo chats getting gigs in different countries, Djing and Music is 4 LoversWelcome to the BOOST podcast with me, Grahame Farmer.
If this is the first time joining me on the podcast, it all started as part of 100 day challenge which was a need because i was procrastinating for 14 months to start one.
For the past 18 months previously, I’ve been giving out Tips to DJs via my Instagram @grahamefarmer since then we set up our BOOST 1to1 Coaching service, we’ve had BOOST breakfasts at IMS and BMC. We have a BOOST weapons release series for artists on my 1to1 Coaching and now this BOOST podcast.
2019-09-0549 minMusic Talk : Music Industry Interviews, Advice and tips for DJs & Producers015 - Social Media Gig ChecklistThis is BOOST a podcast with me, Grahame Farmer. For the past 18 months, I’ve been giving out Tips to DJs via my Instagram @grahamefarmer since then we set up our BOOST 1to1 Coaching service, we’ve had BOOST breakfasts at IMS and BMC. Now I have this podcast, BOOST, its a chance for me to give tips, motivation and maybe a few guest interviews along the way.
Yesterday I chatted through some tips for Instagram stories, how did you get on with them? Tag me and i’ll repost them to mine @grahamefarmer
Today, I was pl...2019-08-0122 minMusic Talk : Music Industry Interviews, Advice and tips for DJs & Producers006 - Ralf Kollmann chats about running Mobilee Records & Building SchoolsWelcome to Boost, a podcast with me, Grahame Farmer.
For the past 18 months, I’ve been giving out Tips to DJs via my Instagram @grahamefarmer since then we set up our BOOST 1to1 Coaching service, we’ve had BOOST breakfasts at IMS and BMC.
And now we have a brand new podcast, BOOST.
This podcast is going to me, giving tips, motivation and maybe a few guest interviews along the way. Yesterday I spoke about the sleeping giant of the music industry being Amazon Music if you haven’t listened to that one, go and ch...2019-07-1939 minMusic Talk : Music Industry Interviews, Advice and tips for DJs & Producers005 - Is Amazon Music the Sleeping Giant of the Music Industry?Welcome to the Daily Boost Podcast with me, Grahame Farmer.
For the past 18 months, I’ve been giving out Tips to DJs via my Instagram @grahamefarmer since then we set up our BOOST 1to1 Coaching service, we’ve had BOOST breakfasts at IMS and BMC.
And now we have a brand new podcast the Daily BOOST. This podcast is going to me, giving tips, motivation and maybe a few guest interviews along the way.
Yesterday I spoke with Ellie Talebian about Mental Health and today i wanted to speak about subject that i’ve bee...2019-07-1806 minMusic Talk : Music Industry Interviews, Advice and tips for DJs & Producers004 - Mental Health Training with Ellie TalebianWelcome to the BOOST Podcast with me, Grahame Farmer. For the past 18 months, I’ve been giving out Tips to DJs via my Instagram grahamefarmer since then we set up our BOOST 1to1 Coaching service, we’ve had BOOST breakfasts at IMS and BMC.
And now we have a brand new podcast, BOOST. This podcast is going to me, giving tips, motivation and maybe a few guest interviews along the way.
On the third episode of BOOST, I welcome Ellie Talebian. Amongst many things, Ellie is the managing director of Eclectic Toolbox. They are on a missi...2019-07-1732 minMusic Talk : Music Industry Interviews, Advice and tips for DJs & Producers003 - Podcasting & Radio Presenting with Katie KnightWelcome to the BOOST Podcast with me, Grahame Farmer. For the past 18 months, I’ve been giving out Tips to DJs via my Instagram grahamefarmer since then we set up our BOOST 1to1 Coaching service, we’ve had BOOST breakfasts at IMS and BMC.
And now we have a brand new podcast the Daily BOOST. This podcast is going to me, giving tips, motivation and maybe a few guest interviews along the way.
On the second episode of BOOST, I welcome Ibiza based Katie Knight. Katie is Presenter at Ibiza Global Radio, she hosts her very ow...2019-07-1633 min
Adventures in DowsingAiD052: Ned Wolf – Nandia’s CopperAmerican dowser and author Ned Wolf joins
us from Flagstaff, Arizona to talk about his work as a healer and his new
dowsing-related children’s books “The Nandia Trilogy”.
Plus, the latest dowsing news, and Grahame has a bit of a rant (56 mins, 40MB).
Visit Ned's website: Nandia's Copper2017-12-0256 min