The Court of Appeal upheld the findings of the lower tax tribunals that the taxpayer, Thomas Good, who had invested in the film scheme, was subject to income tax on certain ‘minimum annual payments’ (MAP).

Thomas Good, the appellant, invested £300,000 in a film rights scheme in 2007, and increased his stake through a loan offered by the scheme operators, Scion Structured Products Ltd.

Scion promoted a number of tax schemes for films such as Atonement, Eastern Promises and Mr Bean's Holiday.