- Court of Appeal holds film partnerships not trading and rejects judicial review application (Samarkand Film v HMRC)
- Original news
- What are the practical implications of this case?
- What was this case about?
- What did the court decide?
- Judicial review
- What should tax lawyers take note of?
- Case details
Tax analysis: The Court of Appeal upheld the decisions of the First-tier Tax Tribunal (FTT) and the Upper Tribunal (UT) that two film scheme partnerships were not carrying on a trade, meaning the individual investors were unable to benefit from certain tax reliefs. In addition, the partnerships’ application for judicial review, citing legitimate expectation based on HMRC’s Business Income Manual (BIM), was rejected.
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