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.

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

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.

In this episode Harriet and Grahame discuss Pillars 1 and 2 with Professor Hans van den Hurk ...

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 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.

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?

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.