Court of Appeal decision in Ingenious litigation

The Court of Appeal has allowed the appeals of Ingenious Films and Inside Track against the decision of the Upper Tribunal.  In doing so, the Court has provided much needed clarity to the determination of the existence of a trade for tax purposes and when such a trade will be carried on with a view to profit.

Jonathan Peacock QC acted for Ingenious, together with Richard Vallat QC, James Rivett QC and Edward Waldegrave