Speed Read: In the Icebreaker case Icebreaker contended that the expenditure that it had incurred on its first day of trading in film production and distribution gave rise to allowable losses which Icebreaker's members could set off by way of sideways loss relief against other income arising outside the trade. The First-tier Tribunal dismissed Icebreaker's appeal holding that the bulk of the expenditure had nothing to do with Icebreaker's trade but was 'basically inserted into the structure to ramp up the apparent spending on trading items in order to increase the initial tax relief available to the LLP and its members'.
A number of issues arise from the decision of the Tribunal in Icebreaker 1 LLP v HMRC [2010] UKFTT 6 (TC). These include:
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Speed Read: In the Icebreaker case Icebreaker contended that the expenditure that it had incurred on its first day of trading in film production and distribution gave rise to allowable losses which Icebreaker's members could set off by way of sideways loss relief against other income arising outside the trade. The First-tier Tribunal dismissed Icebreaker's appeal holding that the bulk of the expenditure had nothing to do with Icebreaker's trade but was 'basically inserted into the structure to ramp up the apparent spending on trading items in order to increase the initial tax relief available to the LLP and its members'.
A number of issues arise from the decision of the Tribunal in Icebreaker 1 LLP v HMRC [2010] UKFTT 6 (TC). These include:
● ...
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:
