TC09613 - [2025] UKFTT 00989 (TC)

Mr Burley told us that in about 2001 he was persuaded to invest in two “film schemes” (the Partnerships), which were presented to him as having the effect of reducing his personal tax liability by making use of government incentives to invest in the film industry. He does not recall it being made clear to him that, if the films were successful, he would be obliged to pay tax on the proceeds even though those proceeds were not paid to him but were instead applied in reducing associated bank loans. He was therefore faced with unexpected tax liabilities when the films returned profits. He and his accountant (Mr McErlean) met with Alan Pink of Alan Pink Tax who suggested that the interest Mr Burley had in the Partnerships could be introduced to the LLP and those profits could be attributed to CBL which would then bear tax at a lower rate.