Wednesday 19 – Thursday 20 October 2022
This is a second appeal. By appellant’s notice filed on 13 January 2022, the taxpayer appellant appeals, with the permission of UT Judges Mr Justice Michael Green and Judge Thomas Scott, their order of 18 November 2021, whereby they dismissed his appeal against the decision of the First-tier Tribunal.
The FTT determined that the appellant was liable to income tax on certain Minimum Annual Payments (MAPS) received under a scheme for the exploitation of film rights in which he had participated.
The issue in this case is whether the MAPs were income from a non-trade business which he received or was entitled to within the terms of section 611 of the Income Tax (Trading and Other Income) Act 2005.