Revenue blocks Ingenious film loss relief

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Business leaders, sports stars and celebrities including footballer David Beckham, singer Bob Geldof and Lucian Grainge, chief executive of Universal Media Group, are likely to be caught up in yet another film partnership tribunal hearing, reports Nick Huber.

The partnerships, which have attracted more than £700m, invest in the making of films such as Avatar, computer games such as Dirt, one of the rally racing game series backed by driver Colin McRae, according to the Financial Times. Other people who reportedly invested include footballer Wayne Rooney, cricketer Andrew Flintoff, and composer Andrew Lloyd Webber.

Following a lengthy stand-off during which HMRC said it was investigating the arrangements of film partnerships operated by Ingenious, the media company said in a letter to investors that it had requested closure notices from HMRC in order for it to put the cases forward for hearing at the first tier tax tribunal. 

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28th Sep 2012 13:48

i dont think this one will run

my money is on ingenious

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28th Sep 2012 14:18

nor I

The odds on Ing v HMRC are pretty good; are ladbooks offering odds? Their schemes never sailed ouside the limits in my experience whereas it was the blatant attempt of other producers and promoters that tipped over the apple cart.

Good products such as Band of Brothers and Shakleton wer made with early FP funding but reruns of Coronation Street and attempt to use film clips for mobile phones? Com'on!

It was hardly surprising the DCMS got ansy

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01st Oct 2012 11:44

Time taken to get to Tribunal

It is interesting that the appellants note that they expect to get to the FTT "towards the end of 2013 i.e. there could be a 15 months delay.

I understand from speaking to others that the listing time for the FTT is now about 76 weeks. Given that the listing may follow say two or three years of correspondence/internal reviews etc before the impasse has been reached and there could be several more years of delay if HMRC loose at the FTT and appeal to the High Court and beyond the wheels of justice now appear to be moving very slowly. 

It has been suggested to me by a firm specialising in enquiry work that there are 20,000 unresolved cases stacked up awaiting a FTT hearing.

It would be interesting to know whether others have more concrete and first hand information about the FTT's workload.






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01st Oct 2012 14:14

Misleading headline?

I'm not sure that the headline goes with the rest of this story.

As far as I can see HMRC haven't refused the tax relief.......they've just refused to make a decision!

Having looked at the Ingenious Investment documentation and track record I can't see how HMRC can say that the partnerships aren't set up to trade at a profit.

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01st Oct 2012 15:33

and to think...

i thought this line up of celebs were simply trying to avoid tax using a scheme set up specifically with them in mind...but actually they have an express interest in helping the uk film industry thrive, and to do so are willing to throw money at these projects without any expectation of a return.


cynical moi?!

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02nd Oct 2012 11:59

@justso - oh yes you you are!

and to think they might have made a profit as well............ not trading mmmm

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02nd Oct 2012 12:01

what really gets up HMRC noses

is the gearing up of investmenst by borrowing - this was pioneered , on a grand scale,  by the property enterprise trusts back  in late 80s and early 90 s

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08th May 2015 03:52

John Harbord Hamond Director of Patrick McKenna's Ingenious Film Partnership 2 LLP losses were recorded from 2010 to 2011 of circa GBP 400m. If the Police had done thier job properly in 2010, his asetts would have been frozen and the alarm raised before investors lost so many hundreds of millions. See John Harbord Hamond Theft:

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