- Court of Appeal restores first instance decision on trading with a view to profit (Ingenious Games v HMRC)
- Why it matters
- Case details
Tax analysis: In Ingenious Games, the Court of Appeal (CA) restored the First-tier Tax Tribunal (FTT) decisions that the film partnerships were trading and doing so with a view to a profit (albeit not on the basis argued by the taxpayers), overturning the Upper Tribunal’s (UT) criticisms of the FTT decisions on those points. The FTT’s decision on the games partnership (that it was not trading at all) was also upheld.
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