Ingenious Games LLP and Others and The Commissioners for HM Revenue and Customs:[2019] UKUT 0226 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Falk and Judge Herrington on 26 July 2019.
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INCOME TAX AND CORPORATION TAX 鈥撯�� LLPs established to carry on activities relating to the production of films and games 鈥� individual members of the LLPs making capital contributions for membership 鈥� funding also coming from commissioning distributor 鈥� Whether activities carried on by the LLPs constituted a trade 鈥� Whether activities of the LLPs carried on with a view to profit 鈥� Whether expenditure incurred by the LLPs equal to 100% of production budget of film or game 鈥� Whether expenditure incurred wholly or exclusively for purposes of LLPs鈥� trade 鈥� Whether LLPs鈥� accounts compiled in accordance with generally accepted accounting practice 鈥� Whether LLPs鈥� expenditure on film and games rights was capital expenditure for tax purposes 鈥� Income Tax (Trading and Other Income) Act 2005, ss 25, 26, 33, 34, 863 鈥� Corporation Tax Act 2009 ss 46, 47, 53, 54, 1262, 1273.