Lee Ellis (Stewarts Law) analyses the tribunal’s supplemental decision that ‘the rights’ to income from the investments made by the Ingenious LLPs were capital in nature and its likely contentious future.
Background
In a decision of 2 August 2016 (Ingenious Film Partners 2 LLP [2016] UKFTT 521 (TC)) the First-tier Tribunal (FTT) held that the various Ingenious LLPs (except for Ingenious Games LLP) were trading and that those trades were conducted with a view to the making of profit. In the view of the tribunal however the LLPs were only trading and doing so with a view to profit on the basis that the trade involved only 30% (or 35% depending on the LLP) of the production cost of the relevant film(s) in return for a 30% (or 35%) share of the net receipts generated from the exploitation of the film(s) rather than the full...
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Lee Ellis (Stewarts Law) analyses the tribunal’s supplemental decision that ‘the rights’ to income from the investments made by the Ingenious LLPs were capital in nature and its likely contentious future.
Background
In a decision of 2 August 2016 (Ingenious Film Partners 2 LLP [2016] UKFTT 521 (TC)) the First-tier Tribunal (FTT) held that the various Ingenious LLPs (except for Ingenious Games LLP) were trading and that those trades were conducted with a view to the making of profit. In the view of the tribunal however the LLPs were only trading and doing so with a view to profit on the basis that the trade involved only 30% (or 35% depending on the LLP) of the production cost of the relevant film(s) in return for a 30% (or 35%) share of the net receipts generated from the exploitation of the film(s) rather than the full...
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