Courts back HMRC in latest £480m film tax judicial review

Investors include David Beckham and Gary Lineker

Victoria McKeever
clock • 1 min read

HM Revenue & Customs (HMRC) has won a judicial review of accelerated payment notices (APNs) and partner payment notices (PPNs) against investors in the Ingenious Media film tax schemes.

Claimants in the tax case had appealed against the High Court judgement on the lawfulness of APNs and PPNs issued by HMRC, requiring investors to pay the owed tax on the film partnership investments. It was argued the cases were on a range of public law challenges and whether before issuing the APNs, the designated officer (DO) was required to determine to the best of his information and belief that the schemes did not work. Claimants also argued HMRC had breached claimants' human rights in issuing the APNs. In December, however, the Court of Appeal dismissed the appeal. It ruled t...

To continue reading this article...

Join Professional Adviser for free

  • Unlimited access to real-time news, industry insights and market intelligence
  • Stay ahead of the curve with spotlights on emerging trends and technologies
  • Receive breaking news stories straight to your inbox in the daily newsletters
  • Make smart business decisions with the latest developments in regulation, investing retirement and protection
  • Members-only access to the editor’s weekly Friday commentary
  • Be the first to hear about our events and awards programmes

Join

 

Already a Professional Adviser member?

Login

More on Tax planning

Reliable Returns: Foreign equity returns and the growing significance of operational leakage

Reliable Returns: Foreign equity returns and the growing significance of operational leakage

'The strategic case for foreign equity exposure remains compelling'

Steven Everard
clock 27 March 2026 • 4 min read
HMRC apologises for complaints delays

HMRC apologises for complaints delays

Taxpayers face long waits

Laura Miller
clock 26 March 2026 • 2 min read
Majority of UK adults oblivious to pensions IHT change - research

Majority of UK adults oblivious to pensions IHT change - research

Standard Life research finds 89% have little or no awareness about upcoming IHT pension changes

Martin Richmond
clock 24 March 2026 • 3 min read