After 22 days hearing the case earlier this year the Upper Tribunal published at the end of July its decision in Ingenious Games LLP [2019] UKUT 0226 (TCC) also involving Inside Track Productions LLP and Ingenious Film Partners 2 LLP. It’s a lengthy document (though less than a third of the First-tier Tribunal’s gargantuan 1 843 paragraphs) analysing in detail the arguments and counter-arguments put forward by the seven QCs and eight junior counsel involved in the case. Nonetheless the key point could be understood by a child of ten.
The scheme depended upon the ability to offset trading losses against participants’ other income. It was therefore a necessary condition of the scheme that a trade should be carried on. If it was not the edifice that had been carefully and expensively constructed would prove to have been built on sand...
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After 22 days hearing the case earlier this year the Upper Tribunal published at the end of July its decision in Ingenious Games LLP [2019] UKUT 0226 (TCC) also involving Inside Track Productions LLP and Ingenious Film Partners 2 LLP. It’s a lengthy document (though less than a third of the First-tier Tribunal’s gargantuan 1 843 paragraphs) analysing in detail the arguments and counter-arguments put forward by the seven QCs and eight junior counsel involved in the case. Nonetheless the key point could be understood by a child of ten.
The scheme depended upon the ability to offset trading losses against participants’ other income. It was therefore a necessary condition of the scheme that a trade should be carried on. If it was not the edifice that had been carefully and expensively constructed would prove to have been built on sand...
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:
