We are pleased to announce that we were
successful in our appeal to the Special Commissioners in respect of the
partnerships Micro Fusion 2004-1 LLP and Halcyon Films LLP. We attach
an update that was prepared by our lawyers, DLA Piper, setting out
details of the decision.
The
decisions highlight the significance of thorough documentation and
detailed implementation; something that Future takes very seriously. As
DLA state, "The Decisions emphasise the importance of good
implementation and the need to substantiate every assertion made with
sound documentary evidence…taxpayers can be confident that challenges
by HMRC will focus on the facts and the integrity of the implementing
documents."
DLA add, "The hard work
and preparation for both of these appeals, which Halcyon Films LLP and
Micro-Fusion 2004-1 LLP should be commended for, resulted in all
relevant material being put before the Special Commissioners in a
manner that rebutted most of the factual contentions advanced by HMRC."
DLA Piper Tax Litigation Update (PDF)