In Ingenious Games LLP and others v HMRC [2021] EWCA Civ 1180 (4 August 2021) the Court of Appeal (CA) restored the First-tier Tribunal (FTT) decisions that the film partnerships were trading and doing so with a view to a profit 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.