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Aug 6, 2021 · UK tax authority HMRC (HM Revenue and Customs) has lost the latest installment of its complex and long-running legal battle with film financier Ingenious Media, which will now be looking to claw...
- Why Losses Arose
- How Much Loss Was Allowed
- Court of Appeal
Although this has been widely referred to as a “film scheme” case, it does not rely on special rules relating to tax relief for films, but deals with the fundamental question of whether an activity is a trade, and if so whether it is being carried on with a view to profit. Investors typically subscribed 30% of the funds to an LLP, with a further 70...
The FTT held that the LLP was trading with a view to profit, but only to the extent of the 30% invested by the LLP members. On this basis, 30% of the losses would have been available. However, they also decided that most of the costs incurred were capital rather than revenue, so that only about 4% of the losses claimed were allowed. The UT went fur...
The taxpayers were given leave to challenge the UT decision, but only in relation to the key questions of whether the LLP was trading, and if so, whether that trade was being carried on with a view to profit. They were not entitled to challenge the “capital v revenue” decision, and despite strenuous efforts they were not permitted to revisit the fa...
Aug 8, 2016 · The First-tier Tax Tribunal's eagerly awaited decision in the Ingenious film partnerships case has left both parties, Ingenious and HM Revenue & Customs, claiming a victory.
The Court of Appeal decision that handed down on 4th August this year will now enable taxpayers involved in the three Ingenious film partnerships to finally agree their liabilities with HMRC.
Nov 15, 2017 · In August 2016 the Tax Tribunal ruled the Ingenious Media Film partnerships, which were designed to reduce investors’ tax liability, were in fact trading with a view to a profit. This crucial...
Jul 30, 2019 · HMRC has scored a win at the Upper Tribunal as judges rule that the Ingenious film scheme was tax avoidance with the tax authorities expecting to recoup millions in unpaid taxes.
People also ask
Are Ingenious Media film partnerships a legitimate investment?
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Why did the LLP claim 100% of its funds?
Aug 9, 2022 · In mid-July, the Court of Appeal dismissed an attempt by Ingenious Games LLP and other LLP entities, overseen by UK-based Ingenious Group, to gain permission to appeal a case HM Revenue and Customs won at the Upper Tribunal in 2019.
