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SGA Productions Ltd v HMRC

In SGA Productions Ltd v HMRC [2022] UKFTT 46 (TC) (8 February 2022) the FTT held that the company was not entitled to theatre tax relief in respect of stunt and puppet shows which it put on at an amusement park and a zoo. 

The company entered into contracts with the operators of Legoland Windsor and Whipsnade Zoo to provide live shows. It created the shows and was responsible for staging casting and running of each production including hiring and managing performers and other staff. The shows ran several times a day varying from three times a day in low season to five in high season. Payments under the contracts were not dependent on the number of visitors watching the live show and no payments were made directly to the company by visitors to watch them. The company claimed theatre tax relief.

HMRC accepted that the shows...

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