In this episode Harriet and Grahame meet Bill Dodwell, the ex-Tax Director of the Office of Tax Simplification, and now non-executive for HMRC.
They discuss the OTS, its successes and failures, and whether it has left a legacy in the way UK government thinks about tax. Then they move on to discuss the future of tax legislation and administration.
In this episode, Harriet and Grahame discuss the recent court case of Haworth in the English Court of Appeal which made important findings as to the law surrounding Place of Effective Management and Central Management and Control, two critical concepts in international taxation.
In this episode Grahame fights off a terrible case of man flu to soldier on against all the odds and discuss the new side by side agreement between the G7 and the US.
Harriet and Grahame scope out the possible ramifications and rights and wrongs of Trump’s attack on Pillar 2.
In this episode, Grahame and Harriet take a look at the reports "Tax Inspectors without Borders - Ten Years of Hands-on Assistance in Developing Countries".
The full report can be seen here: https://www.undp.org/publications/tax-inspectors-without-borders-ten-years-hands-assistance-developing-countries
In this episode Harriet and Grahame discuss the recent OECD Report Taking Stock of Progress on Transparency and Exchange of Information for Tax Purposes.
The report attempts to take stock of the successes and weaknesses of the international tax information exchange regime. Harriet and Grahame discuss whether the report succeeds and analyse the data within it.
Amongst all that they have a slight frolic off into a discussion of whether or not the CRS always applied to crypto currency and whether the fast approaching Crypto Asset Report Framework was really necessary.
You can find the report here:
https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/07/taking-stock-of-progress-on-transparency-and-exchange-of-information-for-tax-purposes_cf7047a4/afddc8c5-en.pdf
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
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 ... 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)
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 episode is our first reaction to these important proposals... we are both sure we'll be talking about this again!
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?
