Gideon Sanitt (Macfarlanes) examines the decision in Ingenious that provides some guidance as to how courts might determine whether there is a genuine commercial trading arrangement with a view to profit.
On 26 July 2019 the Upper Tribunal (UT) issued its judgment in the appeal of the First-tier Tribunal’s decision in Ingenious Games LLP Inside Track Productions LLP Ingenious Film Partners 2 LLP v HMRC.
In that appeal the appellant LLPs challenged decisions of the FTT (on 2 August 2016 and then 17 May 2017) that denied income losses which the LLPs had claimed as arising in a film production trade.
Commercial reality
The decisions of the UT and the FTT amount to more than 500 pages but at heart they both consider the nature of the LLPs’ activities and whether they...
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:
Gideon Sanitt (Macfarlanes) examines the decision in Ingenious that provides some guidance as to how courts might determine whether there is a genuine commercial trading arrangement with a view to profit.
On 26 July 2019 the Upper Tribunal (UT) issued its judgment in the appeal of the First-tier Tribunal’s decision in Ingenious Games LLP Inside Track Productions LLP Ingenious Film Partners 2 LLP v HMRC.
In that appeal the appellant LLPs challenged decisions of the FTT (on 2 August 2016 and then 17 May 2017) that denied income losses which the LLPs had claimed as arising in a film production trade.
Commercial reality
The decisions of the UT and the FTT amount to more than 500 pages but at heart they both consider the nature of the LLPs’ activities and whether they...
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:
