FTT denies loss relief for a film partnership (The Gala Film Partners, LLP v HMRC)

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Tax analysis: In The Gala Film Partners, LLP v HMRC, the First-tier Tax Tribunal (FTT) disallowed relief in respect of £111m of partnership losses for 2003–04 on the basis that the business was not trading with a view to profit. Loss relief against other income of the individual partners was also denied, as was loan interest relief for buying into the partnership.