Dealing with the consequence of investments into film schemes (and related structures) has taken up huge amounts of judicial time and as the case of T Good v HMRC [2021] UKUT 281 (TCC) (18 November 2021) shows many issues remain open. It is a feature of many schemes that investors never actually receive the income generated from the films because it is used to repay the borrowings which were taken out to finance the film scheme investments in the first place. Here the taxpayer argued that because of this not only had he not received the income but that he was not entitled to it. On that basis he could not be subject to tax on it. The FTT rejected this argument and its decision has been upheld by the UT. The approach that the UT took to the question...
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Dealing with the consequence of investments into film schemes (and related structures) has taken up huge amounts of judicial time and as the case of T Good v HMRC [2021] UKUT 281 (TCC) (18 November 2021) shows many issues remain open. It is a feature of many schemes that investors never actually receive the income generated from the films because it is used to repay the borrowings which were taken out to finance the film scheme investments in the first place. Here the taxpayer argued that because of this not only had he not received the income but that he was not entitled to it. On that basis he could not be subject to tax on it. The FTT rejected this argument and its decision has been upheld by the UT. The approach that the UT took to the question...
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