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P Degorce v HMRC

In P Degorce v HMRC [2017] EWCA Civ 1427 (6 October 2017) the Court of Appeal upheld the UT’s finding that a film scheme failed as the taxpayer had not been trading.

Mr Degorce was a French national who lived in the UK with his family working as a fund manager. His income for the year 2006/07 was expected to be approximately £19m and he had implemented a scheme to produce a trading loss to set off against that income. The scheme known as the Goldcrest Film Scheme involved the acquisition and distribution of film rights an activity which although ‘carried out with a view to being a profitable venture’ was expected to trigger substantial losses in the first year for the purpose of ICTA 1988 s 380(1). HMRC contended that Mr Degorce had not been carrying on a trade but had simply purchased...

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