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Ingenious Film Partners 2: whether deductions are capital or revenue in nature?

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Following its lengthy tribunal decision involving Ingenious Film Partners in August 2016, the tribunal asked the parties to agree ‘the figures’. The parties however were unable to do so, because they disagreed on whether the rights to income from the films were capital or revenue in nature. In a supplemental decision published last month, the tribunal determined that such rights were capital in nature. The effect is considerably detrimental for investors as their tax claims for loss relief are further reduced to close to, if not, zero. Appeals by the Ingenious LLPs and cross-appeals by HMRC now seem inevitable.

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