In Eclipse Film Partners No 35 Llp v HMRC (No 3) (TC01256 – 13 July) a limited liability partnership 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.
In October 2007 HMRC began an enquiry into the partnership’s tax return for 2006/07.
In May 2009 HMRC issued a closure notice determining that the partnership had not been carrying on a trade so that the partners were not entitled to the tax relief which they had claimed.
The partnership appealed and in September 2010 the First-tier Tribunal directed that the case should be listed for a pre-trial review (see Decision TC00713).
HMRC subsequently submitted a witness statement by a chartered...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
In Eclipse Film Partners No 35 Llp v HMRC (No 3) (TC01256 – 13 July) a limited liability partnership 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.
In October 2007 HMRC began an enquiry into the partnership’s tax return for 2006/07.
In May 2009 HMRC issued a closure notice determining that the partnership had not been carrying on a trade so that the partners were not entitled to the tax relief which they had claimed.
The partnership appealed and in September 2010 the First-tier Tribunal directed that the case should be listed for a pre-trial review (see Decision TC00713).
HMRC subsequently submitted a witness statement by a chartered...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
