The Court was asked whether two ‘film scheme’ partnerships, which were marketed to wealthy individuals resident but not domiciled in the United Kingdom who wished to generate substantial first year losses to set against their taxable income, were carrying on a trade. If the partnerships were not trading, the schemes failed to achieve their fiscal objective in accordance with the relevant legislation governing the grant of tax relief for the financing of films.
Judges:
Arden, David Richards, Henderson LJJ
Citations:
[2017] EWCA Civ 77
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 03 February 2022; Ref: scu.577499