Business Tax: Financing of film production
Business Tax: Financing of film production
In Micro Fusion 2004-1 Llp v HMRC (CA – 19 March) the CA has overturned the Ch D decision in favour of HMRC reported at [2009] STC 1741. A limited liability partnership (M) claimed that it had made a substantial loss on a trade of exploitation of films including a loss of more than £13 000 000 on film production and a payment of more than £1 600 000 to a company for 'film consultancy services'.
HMRC rejected the claim considering firstly that M was not trading since it had effectively sold the master negative of the film in question to a distribution company (P); second that because the film had not been completed until after June 2005 any relief to which M was entitled was for 2005/06 rather than 2004/05;...
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:
Business Tax: Financing of film production
Business Tax: Financing of film production
In Micro Fusion 2004-1 Llp v HMRC (CA – 19 March) the CA has overturned the Ch D decision in favour of HMRC reported at [2009] STC 1741. A limited liability partnership (M) claimed that it had made a substantial loss on a trade of exploitation of films including a loss of more than £13 000 000 on film production and a payment of more than £1 600 000 to a company for 'film consultancy services'.
HMRC rejected the claim considering firstly that M was not trading since it had effectively sold the master negative of the film in question to a distribution company (P); second that because the film had not been completed until after June 2005 any relief to which M was entitled was for 2005/06 rather than 2004/05;...
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: