Commentary

B5.505 Film related trading losses and non-active partners

Business tax
Business tax | Commentary

B5.505 Film related trading losses and non-active partners

Business tax | Commentary

Film trades

B5.505 Film related trading losses and non-active partners

An individual who is a non-active partner in a partnership carrying on a trade of exploiting films is already subject to restriction of the losses he may set against general income by reference to the amount of his capital contribution (see B7.522). A non-active partner is a partner who spends on average less than ten hours a week personally engaged in activities of the trade1.

However, to counter specific schemes, a targeted anti-avoidance provision applies in relation to non-active partners joining a film partnership. Sideways losses relief in the first

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