HMRC has won a court battle to stop a film investment partnership called Eclipse Film Partners No 35 LLP from gaining £117m in tax relief.
The partnership, which included wealthy football managers among its members, wanted to claim tax relief on a complicated £1bn deal with Disney.
Manchester United manager Sir Alex Ferguson and former England manager Sven-Göran Eriksson were members of the partnership alongside hedge fund managers, bankers and chief executives.
The partnership had taken out a large loan to acquire distribution rights to certain films and then leased them back to the same film producer, within a short period, for a payment spread over 20 years.
The members of the partnership claimed interest relief on the loans taken out to fund the purchase of the distribution rights.