Film tax relief: In C Hoyle and others v HMRC [2024] UKFTT 1060 (TC) (26 November) the taxpayers took part in film tax schemes under which they invested in LLPs which leased film rights. Their investments were largely funded by loans and the schemes were designed to enable them to claim film tax credits and relief against other income for trading losses but to at least break even over the 15-year course of the leases. An early exit from the LLPs was however potentially advantageous and the taxpayers all did so. They assigned their capital accounts in the LLPs in return for a price sufficient to repay their loans and which was considered not to be taxable. HMRC considered that the payments were chargeable to income tax under ITA 2007 s 797 or alternatively as a capital gain. Section 797 is an anti-avoidance provision specifically aimed at film...
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Film tax relief: In C Hoyle and others v HMRC [2024] UKFTT 1060 (TC) (26 November) the taxpayers took part in film tax schemes under which they invested in LLPs which leased film rights. Their investments were largely funded by loans and the schemes were designed to enable them to claim film tax credits and relief against other income for trading losses but to at least break even over the 15-year course of the leases. An early exit from the LLPs was however potentially advantageous and the taxpayers all did so. They assigned their capital accounts in the LLPs in return for a price sufficient to repay their loans and which was considered not to be taxable. HMRC considered that the payments were chargeable to income tax under ITA 2007 s 797 or alternatively as a capital gain. Section 797 is an anti-avoidance provision specifically aimed at film...
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