High Court dismisses claim for declaratory relief in relation to failed film partnership scheme
In N Barklem v HMRC[2024] EWHC 651 (Ch) (22 March 2024) the High Court (HC) struck out the taxpayer’s claims for declaratory relief the substance of which was a declaration that HMRC notices issued under TMA 1970 s 28B(4) disallowing his claim for sideways relief were invalid.
Mr Barklem (the claimant) was a partner in a film partnership Film 2K Partnership (Film 2K). Film 2K made losses in the tax years 1999/2000 and 2000/01 (the ‘relevant periods’). Those losses were stated to be trading losses and were apportioned between its partners in accordance with TMA 1970 s 12AA. The claimant filed self-assessment tax returns for the relevant period claiming sideways relief for his share of the partnership’s losses under ICTA 1988 ss 380 and 381. In order to claim sideways relief ...
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:
High Court dismisses claim for declaratory relief in relation to failed film partnership scheme
In N Barklem v HMRC[2024] EWHC 651 (Ch) (22 March 2024) the High Court (HC) struck out the taxpayer’s claims for declaratory relief the substance of which was a declaration that HMRC notices issued under TMA 1970 s 28B(4) disallowing his claim for sideways relief were invalid.
Mr Barklem (the claimant) was a partner in a film partnership Film 2K Partnership (Film 2K). Film 2K made losses in the tax years 1999/2000 and 2000/01 (the ‘relevant periods’). Those losses were stated to be trading losses and were apportioned between its partners in accordance with TMA 1970 s 12AA. The claimant filed self-assessment tax returns for the relevant period claiming sideways relief for his share of the partnership’s losses under ICTA 1988 ss 380 and 381. In order to claim sideways relief ...
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:
