Samarkand Film Partnership No 3 and others v The Commissioners for HM Revenue and Customs : [2015] UKUT 0211 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Nugee and Judge Sinfield on 29 April 2015.
Read the full decision in .
INCOME TAX 鈥損artnerships engaging in sale and leaseback of films and partners claiming losses under film acquisition relief provisions ss130-140 ITTOIA 鈥� whether trading - held no - appeal dismissed 鈥� if trading, whether business carried on on a commercial basis 鈥� amount of acquisition expenditure incurred in respect of original master version of The Queen 鈥� whether partnership loss rules s118ZE ICTA restrict use of any loss 鈥� whether Proteus鈥檚 relevant period less than 12 months s138 of ITTOIA 鈥� whether expenditure of a revenue nature JUDICIAL REVIEW 鈥� whether claimants had legitimate expectation derived from HMRC鈥檚 Business Income Manual 鈥� whether claimants had legitimate expectation derived from HMRC鈥檚 settled practice 鈥� whether HMRC acted with conspicuous unfairness.