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
 UKUT 170 (TCC)
Finance (No 2) Act 1992 42, Taxes Management Act 1970 12AC(1)
England and Wales
Appeal from – De Silva and Another, Regina (on The Application of) v HM Revenue and Customs CA 2-Feb-2016
At UTTC – De 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 . .
These lists may be incomplete.
Updated: 19 April 2021; Ref: scu.525880