.png)
.png)
Issue:
4884
/
Categories:
Comment & Analysis
, Business Income Manual
, film tax relief
, HMRC
, tax avoidance
, Avoidance
Box office hits
Key points
- The Scion scheme was disclosed to HMRC in April 2007.
- The scheme involved the acquisition and exploitation of rights in two films.
- The arrangements might be considered highly artificial but that would be an over-simplistic view.
- Once HMRC had defeated a scheme collection of disputed tax in both the defeated and similar schemes became easier.
- The Court of Appeal revisited the decision in Khan v CRC [2021] EWCA 624.
The recent decision of the Court of Appeal in Good v CRC [2023] EWCA Civ 114 concerned the Scion Structured Products Limited Scheme a tax avoidance scheme that involved the acquisition and exploitation of rights in two films ‘Repossession Mambo’ which was later renamed ‘Repo Men’ and ‘Tenure’.
Scion scheme
The Scion scheme was disclosed to HMRC by way of a completed AAG1 – disclosure of avoidance scheme on 27 April 2007 which summarised the...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
