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22 September 2008
Categories:
Tax cases
Halcyon Films LLP (SpC 696)
A limited liability partnership Halcyon Films claimed a loss for 2003-04 of over £14 million including a claim of about £12.1 million under F(No 2)A 1992 s 42 in respect of expenditure of the master negatives of three films. A trading loss of more than £1.8 million attributable to fees paid to LMI for film consultancy services was also included.
HMRC rejected most of the claim allowing only £240 760. They said:
- relief was prevented by virtue of FA 2002 s 101 (restriction of relief for successive acquisitions of the same film);
- the partnership began trading in December 2003 when it acquired its interest in the master negative of the films so the relief claimed for 2003-04 was excessive;
- if relief under s 42 were due certain costs would be disallowed on the basis...
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