Ingenious Film Partners and others v HMRC

Jonathan Davey  of Wilberforce is currently acting as junior to Malcolm Gammie QC of One Essex Court in one of highest value, longest-running and most complex pieces of commercial and tax litigation in a generation.

Part II of the Ingenious trial commences this week, with £1 billion of tax at stake. The central issue is whether or not various partnerships involved in the film and games industries were carrying on a trade with a view to profit, and, if they were not, the tax consequences of the same.