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Decision Number: TC 02573
Appellant: Alchemist (Devil's Gate) Film Partnership
Respondent: The Commissioners for Her Majesty's Revenue & Customs
Chairmen / Special
Commissioners:
Sir Stephen Oliver QC
Date Of Decision: 05/10/2012
Main Category: INCOME TAX/CORPORATION TAX
Main Subcategory: Partnership
Notes: FILMS – Relief for expenditure on production – Deferments –
Unconditional obligation to pay – Contracts between production company
and individual members of production team – Claim for relief by
Partnership – Deferred amounts payable to cast and crew as and when
exploitation income was received from sales agent – No exploitation income
received by Partnership in year of claim – Whether agreement between
production company and Partnership transferred obligation to pay
deferments to Partnership – Whether an unconditional obligation to pay
deferments in year of claim – Appeal dismissed – F(No.2)A 1992 s.42 and
F(No.2)A 1997 s.48 – CAA 2001 s.5(1) and(5)
Decision(s) to Download: TC02573.pdf TC02573.pdf