The tribunal decision in Ingenious Games LLP and others v HMRC may run to more pages and chapters than many of the scripts of the films involved. Containing 13 chapters (not including appendices) and running to 342 pages it will take significant time to consider the whole ruling.
For now it is only possible to determined the headlines.
Taxpayers appeal allowed (but only in part)
The crucial question was whether the partnerships were trading and if so with a view to profit. In many recent cases where this issue has arisen this has been found not to be the case. The tribunal found in the case of all three structures being considered (Inside Track Productions LLP(ITP) Ingenious Film Partners 2 LLP (IFP2) and Ingenious Games LLP (IG)) either they were not carrying on a trade in the case of IG or not trading with a view...
