With more than £3.5bn estimated to be invested in film partnership sale and lease back schemes and other similar arrangements, HMRC appears to see this approach as a cost efficient and quick method of recouping lost tax revenues rather than going down a lengthy litigation process.
The settlement is also available on interest relief schemes that result in a claim to interest relief under S353(1) ICTA 88 which is used as a deduction against general income.
But terms are not being offered involving any partnerships where HMRC has already commenced criminal investigations or where there are strong grounds to assert that none of the tax relief claimed is due.
HMRC stated that if the opportunity is not taken up, “we will continue to progress our enquiries with a view to litigating the partnership to an accelerated timescale”.
There is no deadline for acceptance, but “as litigation nears it will become more likely that we will consider the dispute is no longer appropriate for this settlement opportunity”, the revenue added.
The government announced additional investment in HMRC to clamp down on tax avoidance and evasion on 3 December.
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