FTT Judgment

On 2nd August 2016 the First-tier Tax Tribunal released its long awaited judgment in the matter of Ingenious Games & Ors v HMRC.

The FTT Judgment will be of application to the following Partnerships:

  • Inside Track 1 LLP
  • Inside Track 2 LLP
  • Inside Track 3 LLP
  • Inside Track Productions LLP
  • Ingenious Film Partners LLP
  • Ingenious Film Partners 2 LLP
  • Ingenious Film Partners 3 LLP
  • Ingenious Games LLP

In general terms, the court held that the Ingenious Partnerships did not qualify for the relief claimed, and are instead only entitled to receive a small proportion of that relief.

While the tax consequences for the Ingenious Partnerships and investors have not been finalised, it is likely that very substantial sums will be repayable to HMRC, together with interest since the relief was first claimed and (potentially) penalties. These sums will amount to significant losses for investors.

Please check the News section of this website for further updates.

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