International Tax Bites: Recent Episodes
Grahame Jackson and Harriet Brown
International Tax Bites explores concepts and issues in international taxation. Welcome to a new podcast series by Hassans Partner Grahame Jackson and Harriet Brown of Old Square Tax Chambers...
Grahame and Harriet will discuss some of big concepts news and issues in International Taxation...
Contact: internationaltaxbites@gmail.com
Learn more about Grahame at https://www.gibraltarlaw.com/our-people/grahame-jackson/
Learn more about Harriet at https://www.taxchambers.com/team/harriet-brown/
In 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)
In 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!
This 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.
In 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?
In 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.
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.
In 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 neartly into domestic categories. The case of Memec sets a framework for that approach, Grahame and Harriet examine this and some other countries' approaches.
In 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.
In 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"
In 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 we draw conclusions and decide if we have at least worked out what is required to design the perfect international tax system.
In 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.
In 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.
In 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.
In 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.
This 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 fully and whether or not the OECD or the UN is the better arena for such discussions.
We are very pleased to welcome such a world leader in tax policy, if you enjoy this episode and are new to our mini-series "Designing the Perfect International Tax System" you may well enjoy our Introductory episode and earlier episodes with Dan Neidle, Sam Mitha, Daniel Bunn and Thornton Matheson. You will also find more than 57 full length stand alone episodes of International Tax Bites.
This 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 for further episodes in this ongoing series. If you are new to the series feel free to go back to the introductory episode.
This 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 ongoing series. If you are new to the series feel free to go back to the introductory episode.
In 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 importing countries, the role of the OECD secretariat and the participation of stakeholders in the process.
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.
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?
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.
In 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.
In 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.
In 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.
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...
In 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.
In 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.
In 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.
In 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
In 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.
In 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.
In 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?
In 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 our Firms and Chambers who have given us the space to do this.
In 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?
In 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.
In 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.
In 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 of 20% of everything over a profit of 10% are awarded to the source state. This was an error, in fact taxing rights of 25% of all margin over 10% are awarded to the source state. Apologies.
In 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)
In 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 Brown
In 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 Brown
In 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.
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".
International Tax Bites and TaxSnax join forces to discuss important International Tax concepts for Bodies Corporate
In 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.
The 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.
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.
In 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.
In 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?
In 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 various vetoes and the abandonment of the proposed directive.
In 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 on post-war Britain including Never Had it So Good, White Heat, Who Dares Wins and State of Emergency. He has made several TV Series for BBC (including “the 70s” and “the 80s with Dominic Sandbrook”). He is the co-presenter of the podcast The Rest is History with Tom Holland. He also writes for the Daily Mail, Sunday Times and has authored a highly successful series of children’s history books called “Adventures in Time”.
In 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 Good, White Heat, Who Dares Wins and State of Emergency. He has made several TV Series for BBC (including “the 70s” and “the 80s with Dominic Sandbrook”). He is the co-presenter of the podcast The Rest is History with Tom Holland. He also writes for the Daily Mail, Sunday Times and has authored a highly successful series of children’s history books called “Adventures in Time”.
In 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 here https://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=1779840
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".
In 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.
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.
The 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.
In this short episode Grahame and Harriet announce the winners of their prize draw for an International Tax Bites mug!
The 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.
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 harriet.brown@itbfiscalis.com or grahame.jackson@itbfiscalis.com.
In 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.
In 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.
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.
In 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 collection
In 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.
In 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 be found here.
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 University Press and Sven’s previous book Leap of Faith a pair of complimentary works which examine the historical causes and science of tax compliance behaviour. What factors influence whether people do or do not pay their taxes.
You can find more information about Sven and John’s work here:
Sven Steinmo | Political Science | University of Colorado Boulder
John D'Attoma – Assistant Professor of Taxation (wordpress.com)
Feel free to contact us on internationaltaxbites@gmail.com
In 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-information
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!
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-information
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-information
In 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.
In 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 Grahame:
Harriet Brown | Specialist Tax Barrister | Tax Chambers
Grahame Jackson - Tax Partner at Hassans International Law Firm (gibraltarlaw.com)
Grahame and Harriet are the authors of the recent text:
A Practitioners Guide to International Tax Information Exchange Regimes published by Spiramus Press and available from www.spiramus.com
In 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.
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 on 1st September 2021 and is available to pre-order here: https://spiramus.com/automatic-exchange-of-information
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.
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.
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.
In 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.com
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.
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.
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!
International Tax Bites explores concepts and issues in international taxation. In this episode Grahame and Harriet discuss the complexities of establishing domicile.
International 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.
Welcome 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.