De Silva and Another v Revenue and Customs: UTTC 15 Apr 2014

Film partnerships – partnership trading losses – inclusion of trading losses in partners’ self-assessment tax returns – claims to utilise those losses for carry back relief- means of challenge available to HMRC
[2014] UKUT 170 (TCC)
Bailii
Finance (No 2) Act 1992 42, Taxes Management Act 1970 12AC(1)
England and Wales
Cited by:
Appeal fromDe Silva and Another, Regina (on The Application of) v HM Revenue and Customs CA 2-Feb-2016
. .
At UTTCDe Silva and Another, Regina (on The Application of) v Revenue and Customs SC 15-Nov-2017
The appellants had entered into certain partnerships designed to mitigate liability too income tax by creating trading losses through investments in films. HMRC rejected the claims. HMRC then sought to backdate adjustments to the carry-back claims . .

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Updated: 19 April 2021; Ref: scu.525880