In Eclipse Film Partners No. 35 LLP v HMRC (TC01963 – 1 May) a limited liability partnership (E) entered into a complex series of transactions in relation to the licensing and distribution of film rights. The partners made substantial claims to tax relief under ICTA 1988 s 353. HMRC began an enquiry into E’s tax return for 2006/07 and subsequently issued a closure notice determining that E had not been carrying on a trade so that the partners were not entitled to the tax relief which they had claimed. The First-tier Tribunal reviewed the evidence in detail and dismissed E’s appeal against this decision observing that ‘the profit over a twenty-year period year by year is determined at the outset and is determined without any reference to the success or otherwise of the exploitation of...
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In Eclipse Film Partners No. 35 LLP v HMRC (TC01963 – 1 May) a limited liability partnership (E) entered into a complex series of transactions in relation to the licensing and distribution of film rights. The partners made substantial claims to tax relief under ICTA 1988 s 353. HMRC began an enquiry into E’s tax return for 2006/07 and subsequently issued a closure notice determining that E had not been carrying on a trade so that the partners were not entitled to the tax relief which they had claimed. The First-tier Tribunal reviewed the evidence in detail and dismissed E’s appeal against this decision observing that ‘the profit over a twenty-year period year by year is determined at the outset and is determined without any reference to the success or otherwise of the exploitation of...
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