INCOME TAX AND CORPORATION TAX — LLPs established to carry on activities relating to the production of films and games – individual members of the LLPs making capital contributions for membership – funding also coming from commissioning distributor – Whether activities carried on by the LLPs constituted a trade – Whether activities of the LLPs carried on with a view to profit – Whether expenditure incurred by the LLPs equal to 100% of production budget of film or game – Whether expenditure incurred wholly or exclusively for purposes of LLPs trade – Whether LLPs accounts compiled in accordance with generally accepted accounting practice – Whether LLPs expenditure on film and games rights was capital expenditure for tax purposes – Income Tax (Trading and Other Income) Act 2005, ss 25, 26, 33, 34, 863 – Corporation Tax Act 2009 ss 46, 47, 53, 54, 1262, 1273.
Citations:
[2019] UKUT 226 (TCC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 07 September 2022; Ref: scu.643784