International Tax Bites

In this bonus episode Harriet and Grahame discuss the abolition of Non-Dom announced on the 6th March by Chancellor Jeremy Hunt, some of the detail around trusts and the proposed FIG regime, and the transitional provisions.

They have some comments for advisers and generally for Non-Doms. In addition they look at the changes to the Transfer of Assets Abroad Regime.

In this episode Harriet and Grahame are joined by Professor Rita De La Feria of Leeds University.

Professor De La Feria is a world leading Tax Policy expert who frequently speaks on matters of tax to a wider public audience. In this episode the three of us discuss what tax is for, what the best approach to making tax policy is and the weaknesses of the public discourse around tax.

In this episode Harriet and Grahame talk to Todd Buell of Law 360 about developments in the EU related to tax including #BEFIT #Unshell and all points in between. Will these directives ever see the light of day or is there reform fatigue setting in. Politics will have much influence on this outcome and Todd gives us his feelings about how the future will develop.

This is our last episode of 2023 and we want to thank you all for listening to us for another year. We look forward to seeing you in 2024.

In this episode Harriet and Grahame talk about some surprising results of the #OECD's Corporate Tax Statistics report "Effective Tax Rates of MNEs: New evidence on global low-taxed profit" which shows that more than half of the "undertaxed" profits in the world arise in nominally high tax jurisdictions.

What creates this gap between statutory rates and actual tax paid? Harriet & Grahame discuss the fact tax systems are more than just headline rates and a gap between statutory rates and actual tax paid may actually be unavoidable.

In this episode Grahame and Harriet explore the procedures and issues around international tax information requests which individuals or institutions may receive from their local tax authorities requesting information for foreign tax authorities.

They discuss what a request looks like, what the limits of that request are and whether a recipient can or is indeed obliged to push back against their local tax authorities.

In this episode Grahame and Harriet discuss the proposals from the EU Tax Observatory for a global minimum tax to be imposed on individuals. They discuss the design of such a system and possible alternatives

In this episode Harriet and Grahame discuss the boundaries of international taxation reporting regimes and the need to make reports under the relevant anti-money laundering regimes. They focus on the interaction of CRS, MDR and POCA. They also give you a round up of their ambitious project "Designing the Perfect International Taxation System", an eight episode epic with globally important guests.

In this episode Harriet and Grahame tackle the issue of translations and multilateral international documents, is there an original document or do all official translations carry the same weight?

In anticipation of the 50th Episode of International Tax Bites Harriet and Grahame talk through the last 2 and a half years of tax podcasting, what were their expectations, how long did they think it would last, what are their favourite episodes, and what have they got out of being "leading" international tax podcasters?

What does the future hold and a big thank you to all our listeners. We would especially like to thank; our team in Nic and Cath who have done great things in keeping it together, and to acknowledge the support of our Firms and Chambers who have given us the space to do this.

In this our second ITB Snax, Grahame and Harriet discuss the Quad Island Forum, a cooperation forum for #Jersey, #Guernsey, #IsleofMan and #Gibraltar to pool expertise and best practice in financial crime and investigating serious tax fraud.

In the first of our bitesize episodes ITB Snax...Harriet and Grahame discuss the EU Corporate Own Resources Proposal, how it will help the EU to fund itself and who is going to pay for it.

The UK Notification of Uncertain Tax Treatment Regime. In this episode Harriet and Grahame discuss the new Notification of Uncertain Tax Treatment Regime (or NUTT). They also muse on the status of guidance and the privileging of HMRC's position on disputed tax treatments. Happy New Year to all our listeners.

In this episode Harriet and Grahame discuss the impact of Pillar 2 (the OECD's global minimum tax rate proposal) . After explaining the basics of Pillar 2 they analyse whether Santa will be caught by the net of Pillar 2 and whether this will be a breach of international law surrounding Santa's special status under Article 4 of the Ho-Ho-Ho ECD's Multilateral Convention on Gift Giving Demi Gods.

Listen in for these and other terrible Christmas themed puns. And Harriet surprises Grahame with an on the spot quiz!

Merry Christmas everyone.

In this episode Harriet and Grahame discuss the EU Blacklist, and the 8th November 2022 changes to the backlisting criteria. The EU Code of Conduct Group and its black and greylists are the most effective international listing regime for taxation systems which are considered harmful by the EU. Inclusion on the blacklist can have quite severe economic and reputational consequences for some jurisdictions. Harriet and Grahame discuss whether the listing system is the most equitable approach and what if any weaknesses it may have in its current form.

In this episode Harriet returns to discuss with Grahame the Autumn Statement of 17th November 2022. In terms of tax what has the Chancellor done, how much will it raise and will it work? 

In this episode Harriet and Grahame discuss some of the more commonly phrases in International Tax such as "avoidance" "arm's length" "purpose" and "main purpose" amongst other things. They also discuss the correct location of the apostrophe in "arm's length".

In this the second episode of the Transfer of Assets Abroad Regime discussion Harriet and Grahame discuss the various types of motive defence available to taxpayers. They also compare TOAA to its related but very different capital gains tax charge s86 TCGA.

In this short episode Grahame and Harriet announce the winners of their prize draw for an International Tax Bites mug! 

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 internationaltaxbites@gmail.com.