International Tax Bites

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 d...

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 prof...

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 land...

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 intern...

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 episod...

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 i...

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 Serv...

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 rol...

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 interna...

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...

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 Internationa...

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 i...

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 a...

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? Harr...

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 l...

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