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- On a further appeal to the Upper Tribunal by both the LLPs and HMRC, the Upper Tribunal agreed with HMRC's interpretation of the rules and held that the LLPs were not trading at all, let alone with a view to profit. Following this result, Ingenious then appealed to the Court of Appeal.
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Are ingenious film tax schemes trading with a view to make a profit?
Are film partnerships trading with a view to profit?
Why is HMRC attacking Ingenious Film Partners 2 LLP?
What is a 'film scheme'?
Aug 24, 2021 · The taxpayers claimed that this produced a loss which could be offset against other income. In order for the loss to be available, the loss had to be a trading loss, and the LLP had to be carrying on a trade with a view to profit.
Aug 6, 2021 · In a ruling issued earlier this week, the Court of Appeal concluded that the Ingenious film tax scheme businesses were indeed trading with a view to make a profit.
Aug 16, 2016 · A film investment scheme by Ingenious Media was trading with a “view to a profit”, and therefore was not a tax avoidance scheme, a tax tribunal has ruled. But the amount of tax relief its investors can claim has been capped.
Aug 1, 2019 · The case concerns whether limited liability partnerships involved in the film and games industries were trading with a view to a profit, whether millions of pounds of expenditure was incurred wholly and exclusively for the purposes of the partnerships’ trade, and whether the partnerships’ accounts were drawn up in accordance with generally ...
Aug 7, 2016 · In contrast, the Upper Tribunal on Friday upheld the decision of the First Tier Tribunal that the Icebreaker scheme was not conducting a trade with a view to profit and as such was set up for the sole purpose of avoiding tax, drawing a clear distinction with the Ingenious case.
In Ingenious Games LLP & Ors v HMRC [2021] EWCA Civ 1180, the Court of Appeal (CA) overturned the ruling of the Upper Tribunal that the LLP film and video game tax scheme partnerships were not trading and undertaken with a view to profit, although the original claims for losses were still denied.
Aug 26, 2021 · Two film partnerships were carrying on a trade with a view to profit, meaning that loss relief was available to individual investors, the Court of Appeal has decided, restoring a decision of the First-tier Tribunal (FTT).
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