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Aug 6, 2021 · Ingenious no longer raises funding through EIS but has a large amount of money still under management.
Aug 30, 2023 · In Ingenious Games LLP & Ors v HMRC [2021] EWCA Civ 1180, the Court of Appeal (CA) overturned the ruling of the Upper Tribunal that the LLP film and video game tax scheme partnerships were not trading and undertaken with a view to profit, although the original claims for losses were still denied.
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Ingenious, which said it was offering legitimate investment in the film industry, has been accused by the Revenue of tax avoidance, with a former HMRC boss describing its schemes as “scams for...
The Court of Appeal unanimously agreed that Ingenious Film Partners 2 LLP, Ingenious Games LLP and Inside Track Productions LLP should not be able to reopen a decision on permission to...
- Joanne Faulkner
- Why Losses Arose
- How Much Loss Was Allowed
- Court of Appeal
Although this has been widely referred to as a “film scheme” case, it does not rely on special rules relating to tax relief for films, but deals with the fundamental question of whether an activity is a trade, and if so whether it is being carried on with a view to profit. Investors typically subscribed 30% of the funds to an LLP, with a further 70...
The FTT held that the LLP was trading with a view to profit, but only to the extent of the 30% invested by the LLP members. On this basis, 30% of the losses would have been available. However, they also decided that most of the costs incurred were capital rather than revenue, so that only about 4% of the losses claimed were allowed. The UT went fur...
The taxpayers were given leave to challenge the UT decision, but only in relation to the key questions of whether the LLP was trading, and if so, whether that trade was being carried on with a view to profit. They were not entitled to challenge the “capital v revenue” decision, and despite strenuous efforts they were not permitted to revisit the fa...
Aug 16, 2016 · The first-tier tax tribunal (Ingenious Games LLP, Inside Track Productions Ltd, Ingenious Film Partners 2 LLP v HM Revenue and Customs, TC05270 ), ruled that the Ingenious Media Film partnerships, were trading with a “view to a profit” and were therefore not tax avoidance schemes as HMRC had claimed.
Key people. Patrick McKenna. ( CEO 1998-present) Number of employees. 80. Website. www .theingeniousgroup .co .uk. Ingenious Media (styled as INGENIθUS) is a division of London -based Ingenious Capital Management Limited, also known as Ingenious. The company was founded in 1998 by Patrick McKenna.
