INCOME TAX -‘partnerships engaging in sale and leaseback of films and partners claiming losses under film acquisition relief provisions ss130-140 ITTOIA -‘ whether trading – held no – appeal dismissed -‘ if trading, whether business carried on on a commercial basis’ amount of acquisition expenditure incurred in respect of original master version of The Queen -‘ whether partnership loss rules s118ZE ICTA restrict use of any loss -‘ whether Proteus’s relevant period less than 12 months s138 of ITTOIA -‘ whether expenditure of a revenue nature JUDICIAL REVIEW -‘ whether claimants had legitimate expectation derived from HMRC’s Business Income Manual’ whether claimants had legitimate expectation derived from HMRC’s settled practice -‘ whether HMRC acted with conspicuous unfairness
[2015] UKUT 211 (TCC), [2015] STC 1975, [2015] STC 2135
Bailii
England and Wales
Income Tax
Updated: 19 November 2021; Ref: scu.549087