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
|