Helen Lethaby on the surprise loss for the taxpayer in Samarkand Film Partnership, an update on disguised remuneration, the ECJ stance on VAT treatment of sales of distressed debt, and more.
Trading in partnershipThe First-tier Tribunal’s recent decision in Samarkand Film Partnership No.3 [2011] UKFTT 610 (TC) was unexpected and if upheld on appeal could have wider significance for how the presence of trading or commerciality is determined particularly in the finance leasing context.
The case concerned a film leasing partnership which was set up to invest in certified British films with a view to the individuals who became partners benefiting from the statutory tax relief which was then available for such investments. It...
