Degorce v Revenue and Customs Commissioners

JurisdictionUK Non-devolved
CourtUpper Tribunal (Tax and Chancery Chamber)
Judgment Date24 August 2015
Neutral Citation[2015] UKUT 447 (TCC)
Date24 August 2015

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4 cases
  • Patrick Degorce v The Commissioners for HM Revenue and Customs
    • United Kingdom
    • Court of Appeal (Civil Division)
    • 6 d5 Outubro d5 2017
    ...in support of the same date. In paragraph 4 of the skeleton, under the heading "The Basic Facts", Mr Maugham said this: "4. In 2007/08 [ Mr Degorce] entered into very similar transactions for the purchase of a further six films, also arranged by the Goldcrest Group. These transactions are t......
  • ACAMAR PRODUCTIONS LLP v Her Majesty's Revenue & Customs, TC 08405
    • United Kingdom
    • First-tier Tribunal (Tax Chamber)
    • 17 d4 Fevereiro d4 2022
    ...this case, five years. In our view, the situation in the present case is analogous to that described in Degorce v The Commissioners for Her Majesty’s Revenue and Customs [2016] STC 542 (Degorce UT”) at paragraph [98], where the Upper Tribunal distinguished between, on the one hand, the spec......
  • Ernest Thomson, Terence Worsfold & Richard Mungavin v The Commissioners for Her Majesty's Revenue & Customs, TC 06598
    • United Kingdom
    • First-tier Tribunal (Tax Chamber)
    • 16 d1 Julho d1 2018
    ...which, by themselves could fairly be described as trading will not cast the cloak of trade over the whole structure.” 187. In Degorce v HMRC [2016] STC 542, the Upper Tribunal characterised the distinction as being between: … the transaction which has the character of trading even though it......
  • Jerome Anderson v The Commissioners for Her Majesty's Revenue & Customs, TC 05314
    • United Kingdom
    • First-tier Tribunal (Tax Chamber)
    • 10 d3 Agosto d3 2016
    ...HMRC [2014] SFTD 694 (8) Eclipse Film Partners No 35 LLP v HMRC [2015] EWCA 95. (9) Degorce v HMRC [2013] UKFTT 178 (TC) (10) Degorce v HMRC [2015] UKUT 447 (TCC) 5 Evidence Mr Mr Bold gave oral evidence to the Tribunal and a witness statement dated 29 July 2015. Mr Bold was cross-examined ......
1 firm's commentaries
  • Film Distribution Rights
    • United Kingdom
    • Mondaq UK
    • 7 d1 Dezembro d1 2015
    ...Degorce v HMRC [2015] UKUT 0447 (TCC) the Upper Tribunal (UT) upheld the decision of the First-tier Tribunal (FTT) that Mr Degorce's film distribution activities did not amount to trading, with the consequence that he could not claim sideways relief for losses arising from those The UT obse......