HMRC wins disclosure argument in film tax case

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Limited liability partnerships (LLPs) in a high-profile tax dispute with HMRC will have to disclose more information about their film investment schemes when the case is heard at a tax tribunal.

A date for the case has not been set but it is expected to be in November or December 2014.

In February, the upper-tier tribunal, HMRC v Ingenious Games, Inside Track Productions and Ingenious Film Partners, [2014] UKUT 0062 (TCC) backed HMRC’s argument that the partnerships should disclose more information about the disputed transactions than first agreed.

The Revenue and taxpayers initially agreed to focus on a sample of five films and games and the partnerships disclosed documents relating to just the sample films and games.

But when HMRC realised that it had not seen all documents relating to the matters the taxpayers were relying on, it sought further...

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