International Tax Bites

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.

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.

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.

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.

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

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.

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.

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.

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.

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.