Ashley Greenbank and Nigel Doran consider the lessons for the tax litigation process that can be learned from the decided cases.
There has recently been a spate of tax cases on film partnerships from all the leading categories of film scheme. However they are only the tip of an iceberg. Many cases in the queue will not reach the courts because similar fact cases stand or fall by their lead case. HMRC is also actively tempting investors fed up with the litigation process or fearing long-tail tax liabilities to settlements. This article considers what lessons can be learned from this litigation.
Model scheme
To place a particular film scheme in context it is helpful to have a template scheme in mind. Before the 2007 changes in film tax reliefs a plain vanilla model might have looked like this:
An LLP is formed to acquire for...
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Ashley Greenbank and Nigel Doran consider the lessons for the tax litigation process that can be learned from the decided cases.
There has recently been a spate of tax cases on film partnerships from all the leading categories of film scheme. However they are only the tip of an iceberg. Many cases in the queue will not reach the courts because similar fact cases stand or fall by their lead case. HMRC is also actively tempting investors fed up with the litigation process or fearing long-tail tax liabilities to settlements. This article considers what lessons can be learned from this litigation.
Model scheme
To place a particular film scheme in context it is helpful to have a template scheme in mind. Before the 2007 changes in film tax reliefs a plain vanilla model might have looked like this:
An LLP is formed to acquire for...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
