The appellant, Dr Syed Akhlaq Rizvi, made five claims for enterprise investment scheme (EIS) relief after investing in several film schemes for the tax years ended 5 April 2015, 2016, and 2017. The schemes were related to Kerris Films, Talland Films and Ellenglaze Films, among others.

When he made the claims, he did not hold an ‘EIS3’, the compliance certificate required before a claim for EIS relief can be made. As a result, Rizvi made claims for EIS relief he was not entitled to make, according to HMRC. However, he argued that his accountants should have picked this up.

On 12 March 2021, HMRC raised discovery assessments totalling £254,826 for three tax years from 2015 to 2017 for £90,000 (2015), £89,826 (2016), and £75,000 (2017).

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