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21 September 2015
Issue: 4519 / Categories: Tax cases , Avoidance
P Degorce v CRC, Upper Tribunal (Tax and Chancery Chamber), 24 August 2015
The taxpayer was a hedge fund manager who took part in a tax avoidance scheme known as the “Goldcrest film scheme”. It involved the purchase and immediate assignment of intellectual property rights in two films. He was one of 12 taxpayers who participated and it was agreed that his would be the lead case.
 
He claimed relief under TA 1988 s 380(1) as a result of losses sustained under the scheme. HMRC refused the claim saying the taxpayer’s activities had not amounted to trading.
 
The First-tier Tribunal agreed that the taxpayer had not been trading and said the sole purpose of the scheme was to avoid tax. The taxpayer appealed.
 
The Upper Tribunal accepted the First-tier...

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