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

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...