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  • ORIGINAL BTC katalog 2015 - page 178-179

The whole amount was expended wholly and exclusively for the purposes of the partnership business. The remainder of such fees were capital in nature and therefore not deductible. We have concluded that Proteus did not trade in the period. We have concluded that Samarkand did not trade in the period. Since Proteus had no trade it had no trading losses for which the partner could claim relief in the period to 5 BTC 517 The FTT concluded, at [], that the Appellants were not carrying on a trade and, at [], that if there was a trade, the Appellants were not carrying on the businesses on a commercial basis. The Appellants contend that there was a trade and that it was carried on on a commercial basis.

He also accepted that if the transaction were a purchase of an income stream, like an annuity, then it would be regarded as an investment. The FTT BTC 517 that the transactions were a single composite transaction in which the Appellants purchased an asset which they leased in return for a fixed income stream.

The FTT also found that the transactions in this case could be viewed as a single pre-ordained transaction and the Appellants did not dispute this finding, as sale and leasebacks would generally be pre-ordained. The Appellants relied, BTC 517 they had done in the FTT, on a number of cases BMIF v BTC 517, Ensign Tankers and Micro Fusion that showed that a sale and leaseback which contained pre-ordained elements was still considered to be a trading transaction. The judgments in BMBF showed that a sale and leaseback complete with deposit of the sale proceeds to guarantee the repayment of the rent is a trading transaction even where it is tax-driven. BGE placed the purchase price on deposit with a bank in Jersey which, in turn, deposited it with Barclays Isle of Man.

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The rental payments were guaranteed and the guarantee was secured by a charge over the deposit. Mr Furness submitted that the transaction was very similar to the sale and leaseback of the films in this case. The difference was to be made up by the capital allowances claimed and neither the Court of Appeal nor the House of Lords considered it precluded there being a trade. He submitted that the commerciality of the transactions had BTC 517 be judged in the context of the unrealistic and artificial commercial nature of the statutory scheme intended to encourage taxpayers to engage in this kind of transaction. In this case, the partners paid real money for the films and leased them back, via Haiku, to the sellers.

These were genuine transactions. Certain transactions are, by their nature, trading. In this case, the partnerships bought the films BTC 517 order to produce income by leasing. The partnerships purchased the films in order to do the deals which is trading. He contended that, once the composite transaction approach is set aside, the only permissible conclusion was BTC 517 the partnerships were carrying on a trade.

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He submitted that whether an activity is a trade is a mixed question of law and fact and every case depended on its own facts. BTC 517, on the facts as found, an activity amounts to an adventure in the nature of trade is a question of law but it is very fact-dependent.


The FTT carefully reviewed the facts and came to their conclusion that the partnerships were not carrying on a trade. The FTT were also correct to hold that there was no partnership until the investors had adhered to the partnership. Mr Tallon submitted that the partners were never involved in any negotiations in relation to the purchase and leasing of the films. The FTT was correct to consider whether there was a trade at the time when the partners adhered and, at that time, there was a pre-arranged deal. The BTC 517 never intended to enter into a speculative transaction. The lease rentals had no connection with the value of the rights granted.

The amount of the rentals was simply an arithmetic calculation to return sufficient monies to the partners to enable them to pay off the capital BTC 517 interest. The fact that the partners benefited in their own personal capacity by obtaining tax relief against their private income did not make the transactions by the partnership commercial. He contended that the legislation requires the taxpayers to carry on a trade. The FTT found, at [], that the commercial nature of the agreements was the payment of a lump sum in return for a series of fixed payments over 15 years, which did not on its own give rise to an adventure in the nature of trade.


The FTT further found, at [], that their conclusion was not affected by the possibility of contingent receipts because they were immaterial. Essentially, Mr Tallon submitted that the way in which the partnerships, or Future on their behalf, conducted the activities was so careless or cavalier that it could not be said that sound commercial principles had been employed with the result that the activities were deprived of the necessary commercial character which is the foundation stone of a trade. Mr Tallon submitted that the partnerships had no serious interest in making a profit and so could not be said to be trading at common law. The FTT set out BTC 517 submissions at BTC 517 and rejected them at [] where the FTT observed that disorganisation does not necessarily make something uncommercial.

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