DNDLAW Tax News –  HMRC claims victory in film tax battle

HMRC has claimed victory in a tax avoidance battle over schemes run by Ingenious Film Partnership and Icebreaker, worth more than £820m. The Revenue said the Ingenious scheme tried to use artificial losses arising from backing a range of films, including Avatar, Life of Pi and Die Hard 4. HMRC said both schemes saw users claim more in tax relief than they had invested, a claim disputed by Ingenious, which described the Tax Tribunal decision “arbitrary and subjective”. HMRC said users of the scheme who did not take the opportunity to settle earlier will now face large bills for interest on top of the £43m in unpaid tax resulting from the scheme. Neil Forster, Ingenious CEO, said: “HMRC appears to be deliberately confusing the Ingenious case with other proven tax avoidance schemes and making assertions which are factually wrong. The Ingenious investors received no more tax relief than the cash they invested.” It is thought Ingenious will appeal against the decision.

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