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Some initial thoughts on the much anticipated tribunal decision in the Ingenious case on entitlement to film tax relief.
KEY POINTS
- Decision in Ingenious case was much anticipated by the.
- The LLPs were held to be trading with a view to profit but not on the financial assumptions made by the LLPs.
- Accounting evidence strongly criticised.
- Investors likely to retain an element of relief.
The long-awaited decision of the First-tier Tribunal in the Ingenious appeal (TC5270) is as much as a blockbuster as some of the films that feature in the case. With 47 days of hearings 14 separate barristers and a decision which runs to 1 842 paragraphs over 342 pages this is clearly no ordinary case. Here I can give only some initial thoughts on a decision that took me most of the day to read: in the weeks ahead we will be carrying a more detailed analysis of the judgment and its...
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