- No sideways loss relief for Icebreaker film partners (Seven individuals v HMRC)
- Original news
- What are the practical implications of this case?
- What was this case about?
- Background to this decision
- Questions considered by the Tribunal
- What did the Tribunal decide?
- Commercial basis question
- Active member
- Avoidance arrangements
- Case details
Tax analysis: the Upper Tribunal (UT) has found against the taxpayers in the latest installment of the Icebreaker partnership saga. In this decision, separated out from the Acornwood LLP decision delivered in August 2016, the UT found that the trades being carried on by these representative film partnerships were not carried on a commercial basis and therefore no sideways loss relief was available to the members. In additional comments, the UT also confirmed the First-tier Tax Tribunal’s decision in relation to two related anti-avoidance provisions: that the members were not active members, and that the arrangements had the main purpose, or one of the main purposes, of obtaining sideways loss relief.
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