Film production and sound recordings | Croner-i Tax and Accounting

British film, meaning

Commentary – Tax Reporter ¶715-429

Calculation of profits and losses

Commentary – Tax Reporter ¶715-423

Cessation of trade

Commentary – Tax Reporter ¶715-423

Changes in rules

Commentary – Tax Reporter ¶715-420

Commencement of trade

Commentary – Tax Reporter ¶715-423

Core expenditure, meaning

Commentary – Tax Reporter ¶715-429

Deferred income agreements

Case Law – Revenue and Customs Commissioners v Micro Fusion 2004-1 LLP. [2010] BTC 495 ; Revenue and Customs Commissioners v Micro Fusion 2004-1 LLP; Revenue and Customs Commissioners v Halcyon Films LLP. [2009] BTC 237

Enhanced deductions

Commentary – Tax Reporter ¶715-423

Exploitation, charge to tax

Commentary – Tax Reporter ¶129-240

Film production company, meaning

Commentary – Tax Reporter ¶715-429

Film, meaning

Commentary – Tax Reporter ¶715-429

Film-making activities, meaning

Commentary – Tax Reporter ¶715-429

Generally

Commentary – Tax Reporter ¶715-420

Intended for theatrical release, meaning

Commentary – Tax Reporter ¶715-429

Limited budget films, meaning

Commentary – Tax Reporter ¶715-429

Limited liability partnership, allowable deductions

Case Law – Icebreaker 1 LLP v Revenue and Customs Commissioners. [2011] BTC 1,579 ; [2010] TC 003259

Loss relief (companies)

Commentary – Tax Reporter ¶731-610

Loss relief (individuals)

Capital contribution

Commentary – Tax Reporter ¶263-840 ; Tax Reporter ¶291-310

Claimed losses, meaning

Commentary – Tax Reporter ¶263-830 ; Tax Reporter ¶291-295

Disposal of a right to profits

Commentary – Tax Reporter ¶263-820 ; Tax Reporter ¶291-280

Double counting prevention

Commentary – Tax Reporter ¶263-850 ; Tax Reporter ¶291-325

Film-related loss, meaning

Commentary – Tax Reporter ¶263-830 ; Tax Reporter ¶291-295

Generally

Commentary – Tax Reporter ¶263-800

Loss relief restriction

Generally

Commentary – Tax Reporter ¶715-426

Partnerships

Commentary – Tax Reporter ¶263-500

Sideways relief

Commentary – Tax Reporter ¶261-250

Nature of trade

Partnership did not carry on a trade in the relevant period

Case Law – Eclipse Film Partners (No. 35) LLP v Revenue and Customs Commissioners [2014] BTC 503

Plant and machinery allowances

Commentary – Tax Reporter ¶245-870

Pre-trading expenditure

Commentary – Tax Reporter ¶715-423

Production expenditure, meaning

Commentary – Tax Reporter ¶715-429

Refusal to certify, judicial review

Case Law – Peakviewing (Interactive) Ltd & Ors v Secretary of State for Culture, Media and Sport. [2002] BTC 353

Relief

Commentary – Tax Reporter ¶715-423

Relief for production or acquisition expenditure

Case Law – Revenue and Customs Commissioners v Halcyon Films LLP. [2010] BTC 515

Restriction of relief for successive acquisitions of same film

Case Law – Revenue and Customs Commissioners v Halcyon Films LLP. [2010] BTC 515 ; Revenue and Customs Commissioners v Micro Fusion 2004-1 LLP. [2010] BTC 495 ; Revenue and Customs Commissioners v Micro Fusion 2004-1 LLP; Revenue and Customs Commissioners v Halcyon Films LLP. [2009] BTC 237

Tax avoidance, financing production of feature films and meaning of arrangement

Case Law – Peterson v Inland Revenue Commissioner (New Zealand). [2010] BTC 129

Tax credits

Commentary – Tax Reporter ¶715-423

Technician, Schedule D or E charge

Case Law – Hall (HM Inspector of Taxes) v. Lorimer. [1992] BTC 424 ; Hall (HM Inspector of Taxes) v. Lorimer. [1993] BTC 473

Trading losses, deductible expenditure

Case Law – Icebreaker 1 LLP [2010] TC 00325 ; Icebreaker 1 LLP v Revenue and Customs Commissioners. [2011] BTC 1,579

Trading stock

UK expenditure

Commentary – Tax Reporter ¶715-429