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Eclipsing the LSS
Key points
- HMRC has a new settlement opportunity for members of the Eclipse Film partnership.
- This follows HMRC’s challenge of Eclipse claims in the tax tribunals and this challenge worked its way up to the Court of Appeal.
- The settlement opportunity terms are that such that the taxpayer gives up interest relief claims and pays tax and interest and gives up on any other Eclipse-related litigation. In exchange HMRC will not pursue the argument that tax was due on the right to income.
- Should this settlement opportunity have implications for other tax schemes and more generally for the application of HMRC’s litigation and settlement strategy?
The new settlement opportunity for members of Eclipse Film LLP was reported in Taxation 16 September 2021 page 5. The first part of this article briefly reviews the nature of the opportunity. The second part suggests that...
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