Samarkand Film Partnership No 3 and others v The Commissioners for HM Revenue and Customs : [2015] UKUT 0211 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Nugee and Judge Sinfield on 29 April 2015.

Read the full decision in Samarkand Film Partnership No 3, Proteus Film Partnership No 1, The Partners Of Samarkand, The Partners Of Proteus and A Proteus Partner v The Commissioners for HM Revenue and Customs: [2015] UKUT 0211 (TCC).

INCOME TAX –partnerships engaging in sale and leaseback of films and partners claiming losses under film acquisition relief provisions ss130-140 ITTOIA – whether trading - held no - appeal dismissed – if trading, whether business carried on on a commercial basis – amount of acquisition expenditure incurred in respect of original master version of The Queen – whether partnership loss rules s118ZE ICTA restrict use of any loss – whether Proteus’s relevant period less than 12 months s138 of ITTOIA – whether expenditure of a revenue nature JUDICIAL REVIEW – whether claimants had legitimate expectation derived from HMRC’s Business Income Manual – whether claimants had legitimate expectation derived from HMRC’s settled practice – whether HMRC acted with conspicuous unfairness.

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