London: +44 (0)20 7236 2601
St Albans: +44 (0)1727 869141
Rickmansworth: +44 (0) 1923 771010
Milton Keynes: +44 (0)1908 605552

HMRC win a film scheme case

A well-known film tax planning scheme whose participants included many public personalities (think Sir Alex Ferguson) was recently confirmed as a tax avoidance scheme.  The Court of Appeal ruled in HMRC’s favour that the scheme, in reality, amounted to tax avoidance.

The planning, which sought to create substantial interest relief claims, saw investors borrowing significant sums of money and claiming against their other income, on the grounds that the loan was made to a trading partnership.  However, it was held that, in reality, the borrowed money simply earned interest, which was then filtered through to investors to cover the interest on their loans.

The Court of Appeal held that the partnership was not trading and as a result investors are not eligible for interest relief; however the profits from the partnerships remain taxable.



Date: 16th March, 2015
Author: Cathy Corns


Articles from this Author

Contact Business Service Partners

Choose from the drop down menu below to select a Partner to contact.


Football #finance short-term cost control, profitability and sustainability @mercerhole Andy Turner sheds light on……

Lisa Spearman, Private Client Partner updates on 'Changes to Main Residence Relief from Capital Gains Tax'……



For the latest Mercer & Hole news, visit our LinkedIn page mercer-&-hole

Click here to follow us on LinkedIn