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 la...
27 Mar 202550min
Episode 80 - Familiar concepts and Pillar 2 - Tax Residence
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 ...
20 Mar 202538min
Episode 79 - Familiar concepts and Pillar 2 - the Tax Base
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 t...
14 Mar 202545min
Episode 78 - State Aid through the lens of the Apple Case with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.
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 we...
27 Jan 20251h 20min
Episode 77 - Rachel Reeves and the £22bn Blackhole - Non doms and tax rises - What on earth is happening in the UK?
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 sh...
10 Okt 202455min
Episode 76: International Tax Cooperation Turf War Part II - The UN Strikes Back! with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.
In this episode Harriet and Grahame discuss the recently published Terms of Reference for a United Nations Framework Tax Convention... What is it? How far will it go? Will it succeed? What will happe...
23 Aug 20241h 6min
Ep 70: Determining the UK tax status of non-UK entities, with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown
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 f...
21 Aug 202438min
Ep 75: Pillar 2 - Too Clever by Half, with Prof. Hans van den Hurk - with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown
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 ma...
17 Aug 20241h 5min
