Hartley Foster and Natalie Coope review the decision in Icebreaker and examine its impact on implementing tax structures
On 26 January 2011 the Upper Tax Tribunal (Vos J) (UTT) released its decision in Icebreaker 1 LLP v HMRC [2010] UKUT 477 (TCC). The case was an appeal by Icebreaker in respect of whether Icebreaker’s expenditure incurred on its first day of trading in film production and distribution gave rise to allowable losses which Icebreaker’s individual members could set off by way of sideways loss relief against other income outside the trade. The UTT set aside the decision of the First-tier Tribunal (FTT) and allowed the appeal in part. However the UTT still concluded (albeit on different grounds to the FTT) that the taxpayer should be denied a trading deduction in respect of the bulk of the expenditure.
We commented on the FTT’s decision in a previous article...
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Hartley Foster and Natalie Coope review the decision in Icebreaker and examine its impact on implementing tax structures
On 26 January 2011 the Upper Tax Tribunal (Vos J) (UTT) released its decision in Icebreaker 1 LLP v HMRC [2010] UKUT 477 (TCC). The case was an appeal by Icebreaker in respect of whether Icebreaker’s expenditure incurred on its first day of trading in film production and distribution gave rise to allowable losses which Icebreaker’s individual members could set off by way of sideways loss relief against other income outside the trade. The UTT set aside the decision of the First-tier Tribunal (FTT) and allowed the appeal in part. However the UTT still concluded (albeit on different grounds to the FTT) that the taxpayer should be denied a trading deduction in respect of the bulk of the expenditure.
We commented on the FTT’s decision in a previous article...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
