- Film and games production LLPs not trading ‘with a view to profit’ (Ingenious Games LLP, Inside Track Productions LLP, Ingenious Film Partners 2 LLP v HMRC)
- What are the practical implications of this case?
- What was the background?
- What did the court decide?
- Case details
Tax analysis: The Upper Tribunal (UT) has dismissed the taxpayers’ appeals and allowed HMRC’s cross-appeal from earlier decisions of the First-Tier Tribunal (FTT) with the result that two LLPs involved with film financing and production and an LLP involved in video game financing and production were not trading, so could not create tax losses for investors in the LLPs. The LLPs were also not carrying on a business ‘with a view to profit’ so even if they were trading, they were not UK tax-transparent and investors could not therefore access their losses.
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