UK Court Finds Tax-Dodging Purpose In Film Finance LLPs

Law360 (July 29, 2019, 6:11 PM EDT) -- A financing partnership run by the production company behind “Avatar” and other movies was hit Friday by a U.K. tax tribunal's finding that a lower court ruled properly in concluding the partnership was mainly a tax-avoidance scheme.

The Upper Tribunal of Britain's Tax and Chancery Chamber sided with the First-Tier Tribunal, which in May 2017 found that Ingenious Games LLP and two of its film investment partnerships weren't conducting a trade or business. As a result, the entities were prohibited from taking tax deductions for certain losses.

The Upper Tribunal's 159-page decision allows HM Revenue & Customs, the U.K. tax authority,...

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