The topic of discussion in this episode is the basics of transfer pricing, what are the transfer pricing rules for, what do they try and tackle and what are the approved methods of calculating transfer prices. This is a basic introduction to a very complex topic and we hope that we have tackled it well.

Most importantly in this episode Harriet and Grahame run a competition for listeners to win an International Tax Bites mug! the question is "What does 'OECD' stand for?" answers by email with your postal address to [email protected].

In this episode Harriet Brown and Grahame Jackson discuss the OECD's proposals to extend the Common Reporting Standard to cover Crypto assets and exchanges. The proposed rules can be found at https://www.oecd.org/tax/exchange-of-tax-information/public-consultation-document-crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard.pdf

Harriet and Grahame discuss which entities will be in scope, what assets will be reportable, and what will be reported on the individuals involved, plus the timeline for implementation.

If you are operating a crypto exchange, or believe you will be obliged to report under the Crypto Asset Reporting Regime, feel free to contact us on [email protected] or [email protected].

In our 25th episode, Harriet Brown and Grahame Jackson spent their morning chatting with the brilliant Filippo Noseda from Mischon de Reya about the boundaries of automatic exchange of information and whether the balance between citizen and state have shifted too far in favour of the state.

In this episode, Harriet and Grahame talk through the Hague Convention related to the International Recognition of Trusts. Which country's laws apply to a trust can have tax consequences but it's generally important as well when trusts deal across borders and may well be subject to consideration by the courts.

In this episode Harriet and Grahame talk about the UK's statutory residence test. When it was introduced in 2013 the SRT was hailed as simplifying what was previously a minefield of uncertainty and a common law test. In fact it is one of the most complex residence tests Harriet and Grahame have ever come across.

In this episode Harriet and Grahame discuss the rules surrounding whether or not countries can recover tax debts through foreign courts. From the original rule in the Government of India case (Government of India v Taylor [1955] AC 491) known as the Revenue Rule through recent case law in SKAT (Skatteforvaltningen v Solo Capital Partners Llp [2022] EWCA Civ 234 (25 February 2022)) and discussing the EU and global agreements which mandate mutual assistance on taxing authorities, Harriet and Grahame discuss the development of cross border assistance in tax collection

In this episode Harriet and Grahame discuss the recent suspension by UK of its tax information exchange relationships with Russia under CRS and Country by Country reporting. They talk about what this could mean for financial institutions. Later on they consider whether the approach of seeking 100% global participation in CRS and other tax exchange regimes is correct especially as professionals may be mandated to collect information that will assist the collecting of tax by countries which behave in unacceptable ways.

In this long anticipated episode of International Tax Bites Harriet Brown and Grahame Jackson talk to Tarik Chebib of Currency.com . They discuss what a crypto asset is (from Bitcoin to NFTs), where it is located, the ways in which it can make you money and the tax consequences of that. Tarik provides technical back up as the guys discuss this conceptually difficult asset class.

Thank you to Currency.com a crypto exchange that provides crypto trading from a regulated platform for their help in producing this episode.

The OECD report that Harriet mentions can be found here.

In Episode 5 of Series 3 Grahame and Harriet are proud to talk to Sven Steinmo and John D’Attoma. Sven is a Professor at University of Colorado Boulder and a leading political scientist who has written several books over the last thirty years and has made significant contributions to the field of social science. John is a research social scientist with the Internal Revenue Service and has previously taught at the University of Exeter Business School and the European University Institute.

In this episode Harriet, Grahame, John and Sven discuss John and Sven’s new book Willing to Pay from Oxford University Press and Sven’s previous book Leap of Faith a pair of complimentary works which examine the historical causes and science of tax compliance behaviour. What factors influence whether people do or do not pay their taxes.

You can find more information about Sven and John’s work here:

Sven Steinmo | Political Science | University of Colorado Boulder

John D'Attoma – Assistant Professor of Taxation (wordpress.com)

Feel free to contact us on [email protected]

In this fourth episode of the latest series, Grahame and Harriet discuss the economic substance tests which have been introduced by the crown dependencies and overseas territories of the UK and other jurisdictions in recent years.  These important provisions are having a major impact on low tax jurisdictions and are an important consideration for those managing or establishing entities in the relevant jurisdictions.

"A Practitioner's Guide to International Automatic Tax Information Exchange Regimes" which will be published on 1st September 2021 and is available to pre-order here: https://spiramus.com/automatic-exchange-of-information