‘Sideways’ loss relief against other income was not available to individual members of ‘Icebreaker’ film partnerships, as the LLP trades were not carried on on a commercial basis and with a view to profit.
An appeal was made by a number of individuals against a decision of the First-tier Tribunal (FTT) in relation to the ‘Icebreaker’ film partnerships (Acornwood LLP v Revenue and Customs [2014] UKFTT 416 (TC)). The appeal raised ‘member level’ issues, which affected the question whether the individual members of the relevant limited liability partnerships (LLPs) could obtain ‘sideways’ loss relief (i.e. offset the individual share of their LLP’s trading losses against other income) for income tax purposes.
The FTT had allowed the LLPs’ appeals to a limited extent, and the losses which they did allow to the four LLPs involved would ultimately amount to
