International Tax Bites

Jan 27 2025 86 ep. 45 mins 19

International Tax Bites Podcast artwork

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: [email protected] 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/

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Episode 78 - State Aid through the lens of the Apple Case with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.

Jan 27 2025 80 mins

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 b

Episode 77 - Rachel Reeves and the £22bn Blackhole - Non doms and tax rises - What on earth is happening in the UK?

Oct 10 2024 55 mins

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 t

Episode 76: International Tax Cooperation Turf War Part II - The UN Strikes Back! with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.

Aug 22 2024 66 mins

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!

Ep 70: Determining the UK tax status of non-UK entities, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown

Aug 21 2024 38 mins

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.

Ep 75: Pillar 2 - Too Clever by Half, with Prof. Hans van den Hurk - with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown

Aug 17 2024 65 mins

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 ext

ITB Snax - Episode 8: Non-Dom reforms with Old Square Tax Chambers' Harriet Brown and Hassans', Grahame Jackson

Aug 01 2024 34 mins

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

Ep 74: The UK-Spain-Gibraltar Tax Treaty - International Tax Bites and Tax Snax with Old Square Tax Chambers' Harriet Brown and Hassans' Grahame Jackson

Jul 24 2024 84 mins

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

Ep 73: The US Green Book - proposals for amendments to GILTI

Jul 17 2024 60 mins

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

Episode 72: Skat and the Revenue Rule - with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown

Jun 26 2024 45 mins

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.

Ep 71: The Webster FATCA Challenge with Old Square Tax Chambers' Harriet Brown and Hassans', Grahame Jackson.

Jun 14 2024 57 mins

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 disqu