International Tax Bites

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 Reg...

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...

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 entitie...

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 t...

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...

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 Curre...

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&nb...

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...

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 pub...

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...

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 episod...

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...

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.