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Articles by Tom McFarlane
Jean-Marie Le Pen: a torturer, a racist, and a political success
Why mourn a torturer? 7 January 2025 marked the day the life of Jean-Marie Le Pen—co-founder and leader up to 2011 of France’s far-right Front National (FN) party—came to a close at 96. Le Pen overcame attachment to a litany of violent crimes over his many years to become a hugely influential figure in French politics.
Clinical Considerations for the Integration of Adjuvant Olaparib into Practice for Early Breast Cancer: A Canadian Perspective
2. Efficacy and Safety of Olaparib in Early Breast Cancer 2.1. The OlympiA Trial: Key Patient Characteristics and Eligibility Criteria OlympiA was a Phase 3, double-blinded, randomized trial evaluating the safety and efficacy of 12 months of adjuvant olaparib therapy versus placebo in high-risk, gBRCA-mutated, HER2-negative early breast cancer following definitive local treatment and adjuvant or neoadjuvant chemotherapy.
Compatibility of UK intra-group transfer rules with EU law
Home >Articles > Compatibility of UK intra-group transfer rules with EU law Compatibility of UK intra-group transfer rules with EU law 14 September 2022 Advocate General (AG) Rantos has opined in Gallaher Ltd v HMRC(Case C‑707/20) that an imposition of an immediate tax charge on asset transfers outside the UK tax net is compatible with EU law.
Five EU members pledge swift implementation of Pillar Two
Home >Articles > Five EU members pledge swift implementation of Pillar Two Five EU members pledge swift implementation of Pillar Two 14 September 2022 France, Germany, Italy, the Netherlands and Spain have issued a joint statement committing to the swift implementation of Pillar Two in the EU 2023 ‘'by any possible legal means’. The statement was issued after an informal meeting of EU finance ministers in Prague on 8 September.
Fiscal event expected next week
Home >Articles > Fiscal event expected next week Fiscal event expected next week 14 September 2022 We await a formal announcement on the date of a fiscal event planned for next week. Although this was initially expected to take place on Wednesday 21 September, it now looks more likely that it may take place on Thursday 22 September or even Friday 23 September (although that would necessitate a delay to the planned rising of the Commons for conference recess).
Amount A of Pillar One consultation
Home >Articles > Amount A of Pillar One consultation Amount A of Pillar One consultation 14 September 2022 The public consultation meeting on the progress report on Amount A of Pillar One held on 12 September focused on the marketing and distribution safe harbour (MDSH) and the elimination of double taxation.
E-Zec Medical Transport Services Ltd v HMRC
Home >Articles > E-Zec Medical Transport Services Ltd v HMRC E-Zec Medical Transport Services Ltd v HMRC 13 September 2022 Private ambulance service qualifies for zero-rating In E-Zec Medical Transport Services Ltd v HMRC [2022] UKFTT TC 857 (25 August 2022), the FTT decided that non-emergency ambulances could qualify for zero-rating, rather than being treated as exempt from VAT. E-Zec Medical Transport Services Ltd...
Coconut Animated Island Ltd v HMRC
Home >Articles > Coconut Animated Island Ltd v HMRC Coconut Animated Island Ltd v HMRC 13 September 2022 Investment reliefs denied In two separate cases – Coconut Animated Island Ltd v HMRC [2022] UKFTT 303 (TC) (CAI) (23 August 2022) and Valyrian Bloodstock Ltd v HMRC [2002] UKFTT 306 (TC) (VB) (25 August 2022) – the FTT dismissed appeals against HMRC notices refusing...
HMRC manual changes: 9 September 2022
Home >Articles > HMRC manual changes: 9 September 2022 8 September 2022 This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors. Direct taxes Manual Page Comments Capital Gains Manual Updated: CG28500 Updated to...
Other cases that caught our eye: 9 September 2022
Home >Articles > Other cases that caught our eye: 9 September 2022 6 September 2022 VAT: composite suppliesIn Spectrum Community Health CIC v HMRC [2022] UKFTT 237 (TC) (1 August 2022) the FTT held that the taxpayer's supplies of various healthcare services to prisoners in England were one single composite supply that was exempt,...
Trust discrepancies and starting new business relationships
Home >Articles > Trust discrepancies and starting new business relationships Trust discrepancies and starting new business relationships 8 September 2022 HMRC has published new guidance in its at TRSM70070 on how to report trust discrepancies by 1 September 2022 which is the deadline for most trusts to be registered on the trust registration service.
Tax morale and the Big Four
Home >Articles > Tax morale and the Big Four Tax morale and the Big Four 8 September 2022 An OECD report, Tax morale II: building trust between tax administrations and large businesses, reveals that routine compliance by large business, MNEs and the Big Four firms was generally perceived to be good, but highlights distrust among tax officials over Big Four tax planning.
Complete overhaul on tax law on cryptoassets required, says CIOT
Home >Articles > Complete overhaul on tax law on cryptoassets required, says CIOT Complete overhaul on tax law on cryptoassets required, says CIOT 8 September 2022 In response to HMRC’s call for evidence on the taxation of decentralised finance involving the lending and staking of cryptoassets, the CIOT has suggested that the government should undertake a complete overhaul of the legislation and guidance concerning cryptoassets and their recognition and treatment by the UK tax system, for...
CIOT calls for improvements in HMRC service levels and warns over MTD
Home >Articles > CIOT calls for improvements in HMRC service levels and warns over MTD CIOT calls for improvements in HMRC service levels and warns over MTD 8 September 2022 CIOT president Susan Ball has repeated calls for increased government investment in HMRC to improve the department’s ‘unacceptable service levels’ which ‘are impacting the finances and cashflow of businesses and individuals and hampering HMRC’s ability to adequately support taxpayers and businesses’.
Tax policy to dominate the political agenda
New Prime Minister Liz Truss has pledged to ‘ride out the storm’ and deliver a ‘pro-growth’ tax-cutting agenda, while also tackling the cost of living crisis. Tax will be ‘front and centre’ of Chancellor Kwasi Kwarteng’s in-tray, noted Tim Sarson, head of tax policy at KPMG.
Uncertain tax treatment, employment status and HMRC’s CEST tool
Home >Articles > Uncertain tax treatment, employment status and HMRC’s CEST tool Uncertain tax treatment, employment status and HMRC’s CEST tool 7 September 2022 If the CEST tool is completed and a contrary view is taken, HMRC must be notified. The employment status of a worker determines how they are taxed.
Priory London Ltd v HMRC; HMRC v Jocoguma Properties Ltd
Home >Articles > Priory London Ltd v HMRC; HMRC v Jocoguma Properties Ltd Priory London Ltd v HMRC; HMRC v Jocoguma Properties Ltd 6 September 2022 Failure to notify daily penalties can be charged retrospectively In Priory London Ltd v HMRC; HMRC v Jocoguma Properties Ltd [2022] UKUT 225 (TCC) (12 August 2022), the UT confirmed that daily penalties for failure to make ATED returns could be charged retrospectively. The two appeals were heard separately by the...
BCM Cayman LP and another v HMRC
Home >Articles > BCM Cayman LP and another v HMRC BCM Cayman LP and another v HMRC 6 September 2022 Limited partnership transactions In BCM Cayman LP and another v HMRC [2022] UKUT 198 (TCC) (BCM Cayman) and HMRC v BlueCrest Capital Management LP and others and A Dodd and others v HMRC [2022] UKUT 200 (22 July 2022), the Upper Tribunal (UT) considered interrelated appeals by HMRC...
Burlington Loan Management DAC v HMRC
Home >Articles > Burlington Loan Management DAC v HMRC Burlington Loan Management DAC v HMRC 6 September 2022 FTT decides treaty shopping provision did not apply In Burlington Loan Management v HMRC [2022] UKFTT 290 (TC) (22 August 2022), the First-tier Tribunal (FTT) held that the appellant was entitled to the exemption from UK withholding tax under the UK/Ireland double tax treaty (DTT) because neither the...
HMRC manual changes: 2 September 2022
Home >Articles > HMRC manual changes: 2 September 2022 1 September 2022 This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors. Direct taxes Manual Page Comments Corporate Intangibles Research and Development...
UK and ITV appeal state aid judgment
Home >Articles > UK and ITV appeal state aid judgment UK and ITV appeal state aid judgment 1 September 2022 understands that both the UK government and ITV are appealing the ruling of the EU General Court (in cases T-363/19 and T-456/19) which held that the controlled foreign companies group financing exemption, as it applied before 2019, constituted state aid.
BlackRock: the transfer pricing aspects
Home >Articles > BlackRock: the transfer pricing aspects BlackRock: the transfer pricing aspects 1 September 2022 There is a potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK. In BlackRock Holdco 5, LLC v HMRC [2022] UKUT 199 (TCC), the borrower (LLC5) was a UK tax resident Delaware LLC in the BlackRock group of companies.
Curtis on discovery assessments
Home >Articles > Curtis on discovery assessments Curtis on discovery assessments 1 September 2022 Too quick off the mark. After a self-assessment return has been filed, there is an ‘enquiry window’ (in most cases one year) during which HMRC may enquire into it. Once the enquiry window for a year has closed, HMRC may remedy any alleged deficiency in the self-assessment only by making a ‘discovery’ assessment.
What does the Inflation Reduction Act mean for US implementation of Pillar Two?
In August, President Joe Biden signed the Inflation Reduction Act (IRA 2022) into law, which he described as ‘one of the most significant laws in our history’. Included among the headline reforms is a 15% ‘corporate alternative minimum tax’ (AMT), which the Joint Committee of Taxation estimates will generate $222bn in revenue over ten years.
Priory London: ATED late filing penalties
Home >Articles > Priory London: ATED late filing penalties Priory London: ATED late filing penalties 1 September 2022 The Upper Tribunal confirms that daily penalties for failure to make ATED returns can be charged retrospectively.
Back to basics on managed services companies
Home >Articles > Back to basics on managed services companies Back to basics on managed services companies 31 August 2022 Thomas Wallace (WTT Consulting) explains how the rules work and what the key risk areas are for advisers. It’s not just IR35 that contractors should be worried about... For more than 20 years now, successive governments have sought ways to tackle the perceived problem around disguised employees. This started with the introduction in April 2000 of the...
HMRC v K Murphy
In HMRC v K Murphy[2022] EWCA Civ 1112 (4 August 2022), the Court of Appeal (CA) held that an amount paid by an employer to settle an employment law claim was taxable and the fact that some of that money was used to pay the claimants’ legal costs, or that it was paid by the employer on the claimants’ behalf to a third party, did not change the character of the payment as earnings.
The art of writing a tax judgment
Home >Articles > The art of writing a tax judgment The art of writing a tax judgment 27 July 2022 As tax law and cases become increasingly complex, it is crucial for judgments to be comprehensible and accessible. Michael Conlon QC considers what makes a good tax judgment - and he explains why, in most tax cases, brevity is but a pious hope. Over the course of my career, I must have read thousands of court and tribunal judgments.
Understanding the Feasibility of Implementing CAR T-Cell Therapies fro
Abstract In Canada, chimeric antigen receptor (CAR) T-cell therapy was recommended for funding for the treatment of select hematological cancers. Canadian hospitals have limited experience and capacity in administrating this therapy. We conducted a qualitative interview-based study with stakeholders in Canada. Questions were asked related to the development, administration, implementation and logistical planning of CAR T-cell therapy.
Impact of Increasing Wait Times on Overall Mortality of Chimeric Antigen Receptor T-Cell Therapy in Large B-Cell Lymphoma: A Discrete Event Simulation Model | JCO Clinical Cancer Informatics
No companion articles DOI: 10.1200/CCI.19.00086 JCO Clinical Cancer Informatics - published online before print October 23, 2019
Tech Tax – Times Are A Changing? | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Harrison: the threshold for ‘deliberate failure’ to file
There are penalties for failure to file a self-assessment tax return on time (unless there is a ‘reasonable excuse’ for the failure): The initial penalty is £100. If the return remains outstanding after three months, penalties of £10 a day (up to a maximum of £900) start to kick in. If it’s still not filed six months after it should have been, a penalty of 5% of the tax due (or a minimum of £300) is payable, with another 5% (or £300) if the delay reaches a year.
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