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Ingenious Film Partners in the Court of Appeal: lights, camera, action!

Heather Self and Hannah Hurley (Blick Rothenberg) examine the key points and the broader implications of the recent Court of Appeal decision.

The Court of Appeal decision in Ingenious Games LLP & others v HMRC [2021] EWCA Civ 1180 issued on 4 August 2021 represents the latest step in the long-running Ingenious Film Partners tax litigation concerning a collection of LLPs related to the Ingenious Media group. The Ingenious Media group (led by Patrick McKenna) was a major player in the world of investments designed to be tax efficient particularly in relation to film schemes during the 1990s and 2000s.

Most film scheme cases relate to specific tax incentives targeted on the film industry (F(No. 2)A 1992 s 42 and the more generous F(No. 2)A 1997 s 48) which accelerated tax deductions for expenditure on film production and acquisition. However in the Ingenious Film...

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