Market leading insight for tax experts
View online issue

Degorce: film schemes and trading

Speed read

Degorce v HMRC is the latest in a line of cases where HMRC has contended that a tax avoidance scheme did not amount to a trade. Historically, HMRC has sought to disallow ‘closed loop’ funding involving loans, but has had little success in the courts on this specific issue. A finding of fact by the tribunal of no trade effectively prevents such planning. Degorce reconfirms that the appellant courts will not overturn findings of facts, except where not to do so would be perverse. In the closing paragraphs of the decision, the door has been left ajar for potentially wider attacks on circular funding.

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top