The hard fought, decade-long dispute between HMRC and the promoters and investors in Ingenious Film Partners 2 LLP (IFP2), Inside Track Productions LLP (ITP) and Ingenious Games LLP reached a mixed result at the First Tier Tribunal in August 2016.

The tribunal recognised that the film partnerships were trading with a view to a profit and were not solely established to avoid tax, but it disallowed the majority of the losses which were claimed by the partnerships. It found that it was unrealistic to compute their profits and losses based on the assumption that they would incur the full budgeted costs of the film. The investors in Ingenious Games had their appeal dismissed.