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
International Tax Bites explores concepts and issues in international taxation. Welcome to a new podcast series by Hassans Partner Grahame Jackson and Harriet Brown of Old Square Tax Chambers...
Grahame and Harriet will discuss some of big concepts news and issues in International Taxation...
Contact: internationaltaxbites@gmail.com
Learn more about Grahame at https://www.gibraltarlaw.com/our-people/grahame-jackson/
Learn more about Harriet at https://www.taxchambers.com/team/harriet-brown/