April’s landmark High Court case against Eclipse Film Partners No 35 LLP, which saw them
prevented from gaining £117m in tax relief, demonstrates to us that HMRC are hardening their
attitude further on tax avoidance schemes.
The partnership included football manager Sir Alex Ferguson alongside other wealthy members
who were claiming tax relief on loans taken out to fund the purchase of the film’s distribution
rights. If tax is a game of two halves, the Government agency certainly left no one in any doubt
who won both in this ruling.