International Tax Bites

Epizode

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  Ep 98: The Side By Side package - what is it, what does it do and where does it come from? 28.07.2026 1h 3min

  In this the 98th episode of International Tax Bites, Harriet and Grahame discuss the OECD Side by Side Package which introduces a number of Pillar 2 related provisions which are not all related to the US.
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  Episode 97: Part 2 - OECD PE Commentary Changes Nov 2025 - Extractive Industries etc. 03.06.2026 55min

  In this episode Harriet and Grahame complete their review of the 2025 revisions to the OECD Model Convention commentary on permanent establishments. This episode sees them discuss the changes to the Commentary around extractive industries whether onshore or offshore.
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  Episode 96: OECD PE Commentary Changes Nov 2025 - Home Working and Permanent Establishments 27.04.2026 1h

  In this episode Harriet and Grahame discuss the recent changes to the OECD Commentary on the Model Double Taxation Convention which expands the thinking around working from home and what constitutes a permanent establishment. This is critical for businesses with decentralised workforces in reducing risk of a PE in the jurisdicitions where they have operatives. This episode is not just for tax teams but also HR teams and those making recruiting decisions
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  Episode 95 Ferrieri and Bonassisa v Italy: The ECHR Strikes back! The boundaries of tax information powers 25.03.2026 1h 19min

  In this episode Harriet and Grahame discuss the recent ECHR case of Ferrieri and Bonnassisa in which taxpayers challenged the Italian regime for requesting confidential financial information from banks inside Italy. The findings laid out the way in which judicial oversight of decision making processes is a vital protection for taxpayers and their Article 8 ECHR rights.
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  Ep 94 - 5th Anniversary special with Kwasi Kwarteng 24.02.2026 1h 18min

  In this the fifth anniversary episode of #ITB, our presenters Harriet Brown and Grahame Jackson interview ex- Chancellor of the Exchequer Kwasi Kwarteng. They discuss Kwasi's life previous to politics, the formation of his political and tax thought, the recoinage crisis of the late 17th Century, what happened during his time as Chancellor and the structural changes to the Office of Budget Responsibility that he thinks are needed to protect the policy making process. Finally they talk about the current tax and financial policy offerings across the UK political spectrum.
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  Episode 93: An Introduction to Indirect Taxes 27.01.2026 1h 5min

  In this episode (in the absence of Harriet) Grahame discusses indirect taxation with Stephen Hodgson of the UK's Betting and Gaming Council.They talk through what an indirect tax is, discuss VAT, how it works and why it is so popular globally. They touch on the US interaction with and misconceptions about VAT and whether VAT can be used as a digital service tax by the back door.
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  Episode 92: How is tax policy made in the UK - Sir Simon Clarke 10.11.2025 1h 1min

  In this episode Harriet and Grahame interview Sir Simon Clarke, who served as both Exchequer Secretary (with responsibility amongst other things for gaming duty and oil taxes) and Chief Secretary to the Treasury in the last Conservative government. They have a wide ranging conversation that focuses on what's it like to be at the heart of the tax decision making process, how is policy made, who initiates it, what is a minister's role and some general chat about what it was like being in the middle of a succession of major international crises from 2019 - 2022.The episode gives a true insight into the depths of expertise and how the system works from a minister's perspective.Sir Simon is now a leading light in Onward UK, Britain's leading centre right think tank.
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  Episode 91: Relocation from the UK to Gibraltar 05.11.2025 19min

  Harriet and Grahame recently spoke at the #GIBLDN25 Gibraltar Government Business Conference. Here we publish the audio of their talk. They focussed on the UK statutory residence test and the relocation options for a person moving to Gibraltar.Whilst they spoke at an HM Government of Gibraltar conference this is not paid content and their views remain their own, not those of HM Government of Gibraltar.
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  Episode 90: The Office of Tax Simplification, Gone But Not Forgotten - with Bill Dodwell 20.10.2025 1h 5min

  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.
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  Episode 89: Place of Effective Management and Central Management and Control 11.09.2025 56min

  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.
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  Episode 88: Pillar 2 "side by side" system. 28.08.2025 32min

  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.
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  Episode 87: Tax Inspectors without Borders - Ten Years of Hands-on Assistance in Developing Countries 21.08.2025 30min

  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
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  Episode 86: OECD Report - Taking Stock of Progress on Transparency and Exchange of Information for Tax Purposes. 15.08.2025 1h 13min

  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
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  Episode 85.. Part 2 of closing in on promoters of marketed tax avoidance 17.04.2025 36min

  In the Spring Statement the Chancellor announced a consultation on reforming the rules around marketed tax avoidance schemes. In this two Part Bonus Episode Harriet and Grahame take a deep dive into the consultation documents.
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  Episode 84 Part 1 of closing in on promoters of marketed tax avoidance 13.04.2025 1h 14min

  In the Spring Statement the Chancellor announced a consultation on reforming the rules around marketed tax avoidance schemes. In this two Part Bonus Episode Harriet and Grahame take a deep dive into the consultation documents.
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  Ep. 83 Familiar Concepts and Pillar 2: Exchange of Info and CbCR 09.04.2025 34min

  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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  Episode 82 - Familiar Concepts and Pillar 2 - Source of Income and Gains 02.04.2025 58min

  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.
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  Episode 81 Familiar Concepts and Pillar 2 - Permanent Establishments 27.03.2025 50min

  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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  Episode 80 - Familiar concepts and Pillar 2 - Tax Residence 20.03.2025 38min

  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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  Episode 79 - Familiar concepts and Pillar 2 - the Tax Base 14.03.2025 45min

  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.