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Saddles for unicorns?
Key points
- Investors were seeking to claim loss relief on investments in films and games.
- HMRC challenges whether the partnerships were carrying on a trade.
- The Upper Tribunal overruled the lower one and held that a trade was not being carried on.
- Partnership members will not be able to claim sideways loss relief.
- The partnerships rather than members could become liable to tax on income without corresponding deductions.
- Ultimately the decision in these cases will help set the boundaries of acceptable tax advantaged investments.
The latest but surely not the last stage in the long-running saga of the tax treatment of the Ingenious film partnerships has seen the publication of the Upper Tribunal’s judgment in the cross appeals from the First-tier Tribunal decision. The substantial case report will augment what is already a huge body of material. By my reckoning the judgments to date total some 580 pages and follow 71 days of hearings. The...
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