[2013] UKUT 0639 (TCC)

[The appeal against this decision is reported at [2015] BTC 10.]

Honourable Mr Justice Sales

Decision released 20 December 2013

Carrying on a trade – Edwards (HMIT) v Bairstow (1955) 36 TC 207 – Jones v First-tier Tribunal [2013] UKSC 19, [2013] 2 AC 48 – business involving the exploitation of films with a view to profit – Income Tax (Trading and Other Income) Act 2005 (‘ITTOIA 2005’), s. 609.

  The Upper Tribunal upheld the decision of the First-tier Tribunal that a film partnership did not carry on a trade in the relevant period.

Summary