EWHC 1082 (2009) HMRC v Micro Fusion and Halycon Films LLP

Film Reliefs - Mixed decision

Case Summary:

These cases both concerned tax planning arrangements in connection with film reliefs. It was held Micro Fusion was not capable of carrying on a trade or business as it held no interest or right in the relevant master negative and so did not get the relief sought. But Halycon did succeed in getting relief under S48 FA ( No2) FA 2007 rather than the more restrictive relief offered by S42 (No2) FA 2007