B5.510 Non-trading income from films and sound recordings
Similar provisions to those in B5.501 to B5.502 apply to income arising from the exploitation of films and sound recordings where those activities do not amount to a trade and, unlike the trading provisions, they continue to apply to both films and sound recordings1. Tax is charged on the full amount of income arising in the tax year. Expenses incurred wholly and exclusively for the purpose of generating the income are deductible, but if expenses would not be allowable if the activities amounted to a trade they are not deductible for these purposes.
A key case on this is the Upper Tribunal decision in Eclipse Film Partners No 35 Llp2. The taxpayer partnership (Eclipse) obtained a 20-year licence from Disney to distribute two films. The business was financed
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