International Tax Bites

• Episode 85.. Part 2 of closing in on promoters of marketed tax avoidance

  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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  36:59
• Episode 84 Part 1 of closing in on promoters of marketed tax avoidance

  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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  1:14:23
• Ep. 83 Familiar Concepts and Pillar 2: Exchange of Info and CbCR

  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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  34:58
• Episode 82 - Familiar Concepts and Pillar 2 - Source of Income and Gains

  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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  58:32
• Episode 81 Familiar Concepts and Pillar 2 - Permanent Establishments

  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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  50:06

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