Released 06 September 2021
HMRC have issued guidance explaining the settlement opportunities for tax owed due to the Tax Tribunals and Court of Appeal finding that Eclipse Film Partners No 35 LLP was not trading.
The Tax Tribunals and Court of Appeal found that Eclipse Film Partners (number 35) LLP was not trading, and as a result, HMRC’s view is that Eclipse members are not entitled to any Eclipse interest relief.
The Courts did not decide the amount of the income from the complex financial arrangements or who would pay tax on it.
View HMRC guidance on the settlement opportunities.
Read the case report R (on the application of Locke) v R & C Commrs  BTC 30.