Harriet Brown and Grahame Jackson are authors of a podcast International Tax Bites that explains different tax concepts. They both in September 2021 released a book "A Practitioner's Guide to International Tax Information Exchange Regimes", published in September 2021 by www.spiramus.com. Harriet practices tax in the UK, but Grahame – in Gibraltar. We discussed their careers, the podcast, the book and the global tax issues at large.
Gibraltar
We start with discovering Hassans International Law Firm where Grahame is a partner. Having the population in Gibraltar of 28,000 people the size of the firm (300 people) is surprisingly large. The firm works a lot with family structures, but Gibraltar is also a world leader in gaming industry.
Jersey
Harriet is a barrister and Jersey advocate @Old Square Tax Chambers in London, but she also practices in Jersey, Guernsey and the Isle of Man. As Harriet is an author of booksThe Jersey Law of Trusts and The Interaction of EU Treaty Freedoms and the UK Tax Code, quite naturally that we dive deeper into the sea of Jersey trusts. She believes that the said islands also have had quite strict rules on identification of clients. Also the information exchange, trust registers, registers of UBOs and other OECD initiatives are changing the landscape of those jurisdictions.
Their new book
We also speak about the process of creating the new book by Harriet and Grahame, and the topic itself – exchange of information – where the world is moving with it, e.g. will the tax authorities be able to process all that info?
CRS
There was an interesting example mentioned by Harriet that HMRC in the UK encouraged voluntary disclosure before it started to get information from the information exchange (CRS) system, which seemed to work successfully, as many thought that HMRS will get the information anyway. However, in this way people highlighted themselves to the HMRC.
Two approaches to the info obtained
There are two approaches by the tax authorities – once they receive an alarm about a certain issue of a person or entity they dive deeper into CRS and other info received from external sources; whereas under the other approach the authorities actively analyse information received under CRS bank account or other reporting. But Harriet thinks that at least the UK authorities are not there yet to be ready to analyse the Big data proactively.
The Latvian case the EUCJ
Grahame explained that a new directive called DAC7 will extend the reporting obligations to online platforms in 2022. He also points to a ‘foreseeable relevant information’ test as to what the tax authorities may request from a business. We discussed the concepts in a context of a Latvian case where the tax authorities requested a used cars sellers’ full data-base from an online platform and they refused, and the case landed in the EU Court of Justice. The same principle applies for info exchange under the tax treaties.
The podcast
Then we switch to their podcast – International Tax Bites. It is not only for tax professionals, but also businesses who would like to learn the international taxation concepts and for students as well, where Harriet and Grahame are just having a chat on the chosen topic. One of the aims of the hosts is to make a dry topic accessible. Grahame highlighted The Tax Professionals Podcast on career development issues of tax experts. Harriet is a fan of podcasts on true crime and horse riding, which she enjoys while walking her dog. Grahame enjoys podcasts on history, e.g. The Rest Is History when walking to his office and back or cooking.
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