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Ingenious Film Partners 2: tribunal recharacterises commercial investments

The tribunal has issued its decision in Ingenious Film Partners 2 LLP.  Gideon Sanitt (Macfarlanes) reviews the consequences of that decision for investors.

‘… that which we call a rose by any other name would smell as sweet’ (Romeo and Juliet cited in the Ingenious Film Partners 2 case report at Chapter VI Section 4)
 
Not if you called ‘em Stenchblossoms’ (Bart Simpson)
 
On 2 August 2016 the First-tier Tribunal issued its decision in Ingenious Games LLP Inside Track Productions LLP Ingenious Film Partners 2 LLP v HMRC (TC 2012/6581; 2013/118; 2013/122).
 
This case has had a contentious history including judicial reviews by Ingenious (R (Ingenious Media Holdings plc and another) v HMRC [2015] EWCA Civ 173) and possible accusations of dishonesty by...

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