International Tax Bites

In this episode Harriet and Grahame complete their review of the 2025 revisions to the OECD Model Convention commentary on permanent establishments. This episode sees them discuss the changes to the Commentary around extractive industries whether onshore or offshore.

In this episode Harriet and Grahame discuss the recent changes to the OECD Commentary on the Model Double Taxation Convention which expands the thinking around working from home and what constitutes a permanent establishment. This is critical for businesses with decentralised workforces in reducing risk of a PE in the jurisdicitions where they have operatives. This episode is not just for tax team...

In this episode Harriet and Grahame discuss the recent ECHR case of Ferrieri and Bonnassisa in which taxpayers challenged the Italian regime for requesting confidential financial information from banks inside Italy. The findings laid out the way in which judicial oversight of decision making processes is a vital protection for taxpayers and their Article 8 ECHR rights.

In this the fifth anniversary episode of #ITB, our presenters Harriet Brown and Grahame Jackson interview ex- Chancellor of the Exchequer Kwasi Kwarteng. They discuss Kwasi's life previous to politics, the formation of his political and tax thought, the recoinage crisis of the late 17th Century, what happened during his time as Chancellor and the structural changes to the Office of Budget Resp...

In this episode (in the absence of Harriet) Grahame discusses indirect taxation with Stephen Hodgson of the UK's Betting and Gaming Council. They talk through what an indirect tax is, discuss VAT, how it works and why it is so popular globally. They touch on the US interaction with and misconceptions about VAT and whether VAT can be used as a digital service tax by the back door.

In this episode Harriet and Grahame interview Sir Simon Clarke, who served as both Exchequer Secretary (with responsibility amongst other things for gaming duty and oil taxes) and Chief Secretary to the Treasury in the last Conservative government. They have a wide ranging conversation that focuses on what's it like to be at the heart of the tax decision making process, how is policy made, who ini...

Harriet and Grahame recently spoke at the #GIBLDN25 Gibraltar Government Business Conference. Here we publish the audio of their talk. They focussed on the UK statutory residence test and the relocation options for a person moving to Gibraltar. Whilst they spoke at an HM Government of Gibraltar conference this is not paid content and their views remain their own, not those of HM Government of Gibr...

In this episode Harriet and Grahame meet Bill Dodwell, the ex-Tax Director of the Office of Tax Simplification, and now non-executive for HMRC. They discuss the OTS, its successes and failures, and whether it has left a legacy in the way UK government thinks about tax. Then they move on to discuss the future of tax legislation and administration.

In this episode, Harriet and Grahame discuss the recent court case of Haworth in the English Court of Appeal which made important findings as to the law surrounding Place of Effective Management and Central Management and Control, two critical concepts in international taxation.

In this episode Grahame fights off a terrible case of man flu to soldier on against all the odds and discuss the new side by side agreement between the G7 and the US. Harriet and Grahame scope out the possible ramifications and rights and wrongs of Trump’s attack on Pillar 2.

In this episode, Grahame and Harriet take a look at the reports "Tax Inspectors without Borders - Ten Years of Hands-on Assistance in Developing Countries". The full report can be seen here: https://www.undp.org/publications/tax-inspectors-without-borders-ten-years-hands-assistance-developing-countries

In this episode Harriet and Grahame discuss the recent OECD Report Taking Stock of Progress on Transparency and Exchange of Information for Tax Purposes. The report attempts to take stock of the successes and weaknesses of the international tax information exchange regime. Harriet and Grahame discuss whether the report succeeds and analyse the data within it. Amongst all that they have a slight fr...

In 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.

In 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.

In 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?

In 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.

In 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 dow...

In 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.

In 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.

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,...

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 e...

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!

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 neatly 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 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 University Hans van den Hurk is an international tax advisor with extensive experience (h...

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 a...