After 48 days of hearings and 342 pages the judicial decision on the validity of the Ingenious business model was handed down. The stakes could not have been higher, on one side was the reputation of probably the most successful and prolific promoter of business models utilising tax mitigation in the UK and on the other side was HMRC who had over £1bn of tax, interest and penalties at risk.

The figures for this one promoter and its three structures under this decision are staggering, £1,620m of losses were claimed by investors and £620m in tax was reclaimed. Those involved in the structures have been identified in the press as including England and Premier League footballers and major figures in the City. The films included Avatar, Hot Fuzz and The Life of Pi.