International Tax Bites
- Folgen
- 108
- Erscheint
- monatlich
- Letzte Folge
- 13. Okt. 2026
Über den Podcast
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/
Folgen 108
Episode 100: International Tax Turf War! The UN First Protocol on the taxation of cross border services.
In this our 100th Episode Harriet and Grahame tackle the recently released draft of the UN's First Protocol on the Taxation of Cropss Border Services. They tackle the document head on and discuss the new and …
Shownotes
In this our 100th Episode Harriet and Grahame tackle the recently released draft of the UN's First Protocol on the Taxation of Cropss Border Services.
They tackle the document head on and discuss the new and some not so new concepts that it introduces to international taxation. As ever they seek to look through the hype at what the docuemtn actually says and examine whether it really is a matter of substance or an early draft that requires quite a lot of work.
Harriet and Grahame would like to thank their loyal listeners over the last 5 years and 8 months that have helped them keep going to get their podcast into triple figures for episodes. The joy of the podcast is to know that people listen and that we can give voice to the concerns and issues which confront all international tax professionals whilst expand both our knowledge and that of our listeners. We are very grateful for you all for trusting us to talk to you for so long about the topic we love.
Episode 99: Title: International Tax Turf War! The UN produces documents…the Zero Draft Framework Convention on International Tax Cooperation
In this the first of a two part episode Harriet and Grahame discuss the Zero Draft Framework Convention on International Tax Cooperation which has been produced byt he UN at their July meeting on international …
Shownotes
In this the first of a two part episode Harriet and Grahame discuss the Zero Draft Framework Convention on International Tax Cooperation which has been produced byt he UN at their July meeting on international tax cooperation.
The document sets out its objectives and principles and establishes the framework which will be fleshed out in later protocols.
Harriet and Grahame discuss the tax credibility of the document in general, the process and stakeholders which have been consulted and whether much of what is covered is already being done succesfully by the OECD.
Ep 98: The Side By Side package - what is it, what does it do and where does it come from?
In this the 98th episode of International Tax Bites, Harriet and Grahame discuss the OECD Side by Side Package which introduces a number of Pillar 2 related provisions which are not all related to the US.
Episode 97: Part 2 - OECD PE Commentary Changes Nov 2025 - Extractive Industries etc.
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 …
Shownotes
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.
Episode 96: OECD PE Commentary Changes Nov 2025 - Home Working and Permanent Establishments
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 …
Shownotes
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 teams but also HR teams and those making recruiting decisions
Episode 95 Ferrieri and Bonassisa v Italy: The ECHR Strikes back! The boundaries of tax information powers
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 …
Shownotes
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.
Ep 94 - 5th Anniversary special with Kwasi Kwarteng
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 …
Shownotes
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 Responsibility that he thinks are needed to protect the policy making process.
Finally they talk about the current tax and financial policy offerings across the UK political spectrum.
Episode 93: An Introduction to Indirect Taxes
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 …
Shownotes
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.
Episode 92: How is tax policy made in the UK - Sir Simon Clarke
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 …
Shownotes
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 initiates it, what is a minister's role and some general chat about what it was like being in the middle of a succession of major international crises from 2019 - 2022.
The episode gives a true insight into the depths of expertise and how the system works from a minister's perspective.
Sir Simon is now a leading light in Onward UK, Britain's leading centre right think tank.
Episode 91: Relocation from the UK to Gibraltar
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 …
Shownotes
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 Gibraltar.
Episode 90: The Office of Tax Simplification, Gone But Not Forgotten - with Bill Dodwell
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 …
Shownotes
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.
Episode 89: Place of Effective Management and Central Management and Control
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 …
Shownotes
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.
Episode 88: Pillar 2 "side by side" system.
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 …
Shownotes
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.
Episode 87: Tax Inspectors without Borders - Ten Years of Hands-on Assistance in Developing Countries
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 …
Shownotes
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
Episode 86: OECD Report - Taking Stock of Progress on Transparency and Exchange of Information for Tax Purposes.
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 …
Shownotes
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 frolic off into a discussion of whether or not the CRS always applied to crypto currency and whether the fast approaching Crypto Asset Report Framework was really necessary.
You can find the report here:
https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/07/taking-stock-of-progress-on-transparency-and-exchange-of-information-for-tax-purposes_cf7047a4/afddc8c5-en.pdf
Episode 85.. Part 2 of closing in on promoters of marketed tax avoidance
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 …
Shownotes
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.Episode 84 Part 1 of closing in on promoters of marketed tax avoidance
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 …
Shownotes
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.Ep. 83 Familiar Concepts and Pillar 2: Exchange of Info and CbCR
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 …
Shownotes
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?Episode 82 - Familiar Concepts and Pillar 2 - Source of Income and Gains
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 …
Shownotes
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.Episode 81 Familiar Concepts and Pillar 2 - Permanent Establishments
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 …
Shownotes
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 down. The definition of PE in Pillar 2 is vitally important for helping not only to identify MNEs but also to help with the calculation of the relevant effective tax rates across the globe. ofEpisode 80 - Familiar concepts and Pillar 2 - Tax Residence
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.
Episode 79 - Familiar concepts and Pillar 2 - the Tax Base
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 …
Shownotes
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.Episode 78 - State Aid through the lens of the Apple Case with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.
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 …
Shownotes
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, it does bring together the principles of State Aid into a single and very important judgment.
Episode 77 - Rachel Reeves and the £22bn Blackhole - Non doms and tax rises - What on earth is happening in the UK?
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 …
Shownotes
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 establishment to make tax policy.
Find more about James here
Episode 76: International Tax Cooperation Turf War Part II - The UN Strikes Back! with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.
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 …
Shownotes
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
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 …
Shownotes
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
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 …
Shownotes
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 extensive experience (hhp.law)
ITB Snax - Episode 8: Non-Dom reforms with Old Square Tax Chambers' Harriet Brown and Hassans', Grahame Jackson
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 …
Shownotes
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 about this again!
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
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 …
Shownotes
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.
Ep 73: The US Green Book - proposals for amendments to GILTI
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 …
Shownotes
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 does the Green Book tell us about the direction of travel for US tax policy in a global context?
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