International Tax Bites

By Grahame Jackson and Harriet Brown

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...

Grah... more

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FAQs about International Tax Bites:

How many episodes does International Tax Bites have?

The podcast currently has 94 episodes available.

International Tax Bites episodes:

April 09, 2025 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 anti-avoidance package?
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35min
April 02, 2025 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 fits with Pillar 2.
...more
59min
March 27, 2025 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 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. of
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51min
March 20, 2025 Episode 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.
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39min
March 14, 2025 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 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.
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46min
January 27, 2025 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 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.
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1h 21min
October 10, 2024 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 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
https://www.shlegal.com/en/people/james-quarmby
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56min
August 23, 2024 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 OECD and the UN don't back down?
All this and more!
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1h 7min
August 21, 2024 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 into domestic categories. The case of Memec sets a framework for that approach, Grahame and Harriet examine this and some other countries' approaches.

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39min
August 17, 2024 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 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)

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1h 6min

FAQs about International Tax Bites:

How many episodes does International Tax Bites have?

The podcast currently has 94 episodes available.

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