The HMRC is currently investigating two high profile film partnerships run buy a number of celebrities and leading businessmen. The HMRC has challenged the partnership structure over concerns that it is not trading for profit. The partnerships made losses in excess of £350m in their first year.
The Limited Liability Partnerships are run by Ingenious Media and include borrowings made between linked businesses. Investors including David Beckham and Bob Geldof could face large tax bills if Ingenious does not win the appeal.
The HMRC are taking a tough stance on film partnerships in their bid to tackle aggressive tax avoidance schemes. This case demonstrates the need for careful tax planning and the importance of engaging a professional tax advisor.