Market leading insight for tax experts
View online issue

Ingenious Games LLP and others v HMRC

In Ingenious Games LLP and others v HMRC [2021] EWCA Civ 1180 (4 August 2021) the Court of Appeal (CA) restored the First-tier Tribunal (FTT) decisions that the film partnerships were trading and doing so with a view to a profit overturning the Upper Tribunal’s (UT) criticisms of the FTT decisions on those points. The FTT’s decision on the Games Partnership (that it was not trading at all) was also upheld.

The background to this case is a series of film and video games partnership investments which were marketed to high net-worth individuals on the basis that among other things the investors would be able to obtain sideways loss relief for any losses generated in the partnerships thereby reducing their underlying personal tax liability.

This appeal concerned only two matters:

  • whether the LLPs were trading; and
  • if they were whether they were trading...

If you or your firm subscribes to, 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 '' for further assistance.