International Tax Bites

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 importan...

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 th...

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....

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....

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 L...

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&...

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...

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. Li...

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 jurisdic...

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 th...

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...

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...

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 th...

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.