Icebreaker – Acornwood LLP and others v HMRC
Published: Friday 5 August 2016
Acornwood LLP and others v HMRC  UKUT 0361 (TCC)
Jonathan Davey QC has won a major victory for HMRC in a high profile tax case. In the appeal of the long running Icebreaker litigation the Upper Tribunal (Mr Justice Nugee) decided all points in favour of Jonathan’s clients. The main issue was whether creative industry limited liability partnerships had incurred millions of pounds of expenditure wholly and exclusively for the purposes of their trade. The Upper Tribunal held that they had not. The purported losses claimed by the 51 LLPs involved ran to approximately £350 million.
Jonathan was leading Imran Afzal (Field Court Tax Chambers), Nicholas Macklam (Radcliffe Chambers) and Sam Chandler (5 Stone Buildings).