HMRC has won its third tax case in a row at the Court of Appeal, says the Financial Times.
This was against a film scheme where £50 million of investors’ money was combined with £840 million of borrowed money to generate huge tax reliefs for wealthy investors. Experts say it is highly significant because the judgement makes it clear that if HMRC has established at a tax tribunal that no trade was being carried out, then the higher Courts are very unlikely to overrule this – exposing many more investors in such schemes to the risk of tax repayments, fines and penalties.