HMRC wins Samarkand film partnership case over tax avoidance

HMRC has won another tax avoidance case against two film leasing schemes, with the Upper Tribunal (UT) agreeing they had not been trading and that the partners were not entitled to sideways loss relief because the businesses of the partnerships were not conducted on a commercial basis with a view to a profit

The tribunal also refused an appeal by the scheme members for a judicial review over allegations HMRC had acted unfairly in its treatment of the schemes.

The case, Samarkand Film Partnership No 3 & Ors v R & C Commrs, etc. [2015] BTC 517, was an appeal to the Upper Tribunal following an earlier decision at a First Tier Tribunal (FTT) in 2012 involving a number of film partnerships [2015] UKUT 0211 (TCC) Appeal number FTC/96-104/2011 Claim number TCC-JR/06/2012.

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