Grahame Jackson

Grahame is a Solicitor, Chartered Tax Adviser and partner with the firm specialising in Tax. He is the leader of the Tax Advisory Team.

After leaving university with his first degree (reading English & Philosophy at Keele) in 1993 he ran his family’s printing business for nine years before moving to Gibraltar.

He joined our associated company management arm, Line Management Services Limited in 2002 as a Company Administrator, moving to Hassans in 2004 to work in the funds department. He began training to be a solicitor in 2004 attending the College of Law and Northumbria University. In 2020 he completed the Chartered Institute of Taxation’s Advanced Diploma in International Taxation. In 2023 he became a Fellow of the Chartered Institute of Taxation after completing the direct route by Body of Work. He has unparalleled experience across the breadth of commercial services provided by the firm.

Grahame is a specialist in both domestic and international tax, working on numerous matters which have a tax element to them, he also has experience of a wide range of matters including business law, personal taxation and residence etc.

Grahame is also Chairman of the Gibraltar Association of Tax Advisors.

In April 2023 Grahame was appointed to the Chartered Institute of Taxation’s prestigious Technical Policy and Oversight Committee: International Taxes Committee. He continues to contribute to policy areas where possible.

Some examples of his work include:

• Advising in respect of international transactions and the interaction of various tax jurisdictions;
• Advising a multi-billion pound property group in relation to the continuing maintenance of corporate structures and corporate governance in a tax setting;
• Advising various clients on the Gibraltar aspects of their businesses and the tax effects of their corporate structures;
• Advising in respect of major group restructures from a trust and tax law perspective;
• Providing assistance with relocation and business establishment for international financial institutions seeking to establish a presence in Gibraltar;
• Advising international groups on double taxation treaty interactions with domestic law;
• Conducting group wide corporate tax compliance reviews coordinating advice from a number of jurisdictions

Grahame is a leading writer on the growing number of international tax information exchange regimes, has spoken at several events on DAC6 and regularly advises financial institutions and fiduciaries on their obligations under DAC6 and CRS. He also the co-presenter of the successful tax podcast International Tax Bites which discusses concepts and issues in international tax, you can listen here.

Publications:

Books:

A Practitioners Guide to International Tax Information Exchange Regimes Harriet Brown & Grahame Jackson, Spiramus Press 2021

On the Principles of Gibraltar Taxation, Levy I and Jackson G R (ed) Spiramus Press 2024

Journal Papers:

1. G Jackson & H. Brown, The Role of Context in Interpreting International Tax Instruments: A Solution to the Erosion of Internal Cohesion of Domestic Tax Systems by International Law? The EU Directive on Administrative Cooperation Version 6 (DAC6) – A Case Study, 76 Bull. Intl. Taxn. 2 (2022),
2. G Jackson & H. Brown, The Common Reporting Standard, the “Managed By” Entity and the Purpose Test, 62 Eur. Taxn. 2 (2022),
3. G Jackson and H Brown,  The Mechanisms for Defeating Tax Avoidance and Acts of Non-Compliance: The Obligation of the State and the International Community to Legitimate Reasonable Taxpayer Choices, European Taxation 2022 (Volume 62) No 6
4. G Jackson The Utility of Tax Residence Tests beyond Taxing Rights and the Concept of “Tests of Belonging” Given the Growing Number of Multilateral Provisions in the Context of Territorial Tax Regimes Bulletin for International Taxation 2022 (Volume 76) No 6
5. G Jackson Let’s Talk about Trust: The Treatment of Foundations as Trusts under the Common Reporting Standard – A Call for a New Approach, Bulletin for International Taxation 2022 (Volume 76) No 9
6. H Brown and G Jackson Interpretation of Multi-lateral Treaties: The Purposive Approach and Multiple Parties Through the Lens of the UK Courts Interpretation of Multi-lateral Treaties: The Purposive Approach and Multiple Parties Through the Lens of the UK Courts Intertax Volume 50 Issue 11 · Oct 5, 2022
7. G Jackson Banks, Automatic Cross-Border Exchange of Taxpayer Information and English Common Law Fiduciary Duties Owed to Customers, Bulletin for International Taxation2023 (Volume 77), No. 1
8. G Jackson and H Brown “The Interaction of the Duty to Make a Suspicious Activity Report under the Proceeds of Crime Act and the Obligation to Report under Hallmark D of DAC6 and the OECD Mandatory Disclosure Regime”, Bulletin for International Taxation (2023) (Volume 77, No 12)
9. G Jackson Understanding the BEPS and Other OECD Tax Initiatives Including the Inclusive Framework in the Context of Treaties and State Inequality Journal of Tax Administration (forthcoming)
10. G Jackson Understanding the Constitutionality of the Actions of the UK When Formulating the Policy Agenda of International Organisations Such as the OECD and the Imposition of International Standards on British Overseas Territories and Crown Dependencies.  Unpublished, available at SSRN as a working paper, May 20^th 20204