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Anti-avoidance measures¹ counter schemes, used by individuals who benefited from the now repealed film tax reliefs (B5.501, B5.502 — which now only applies to sound recordings)², which seek to convert a tax deferral into a permanent tax gain.

These measures continue to apply³ to any individual who claimed sideways relief or capital gains relief (see B8.202, B8.206) in respect of losses arising from such a trade.

They raise a charge to income tax where there is a disposal, after 10 December 2003, of an individual's rights to profits from the trade, and where that disposal is accompanied by the individual either receiving non-taxable consideration, or the amount of his losses claimed becoming greater than his net contribution to the trade. Although there are likely to be very few instances of these provisions now applying, given that the reliefs themselves have long been repealed, they are covered here for the sake of completeness.