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Statement provided to The Sunday Times

10 March 2014

HMRC’s proposals on accelerated tax payments in respect of DOTAS registered arrangements that are under enquiry, as outlined in the recent consultation document, are de facto retrospective, indiscriminate and unfair. This is the view of the Chartered Institute of Taxation (CIOT) and the Institute of Chartered Accountants (ICAEW) as well as ourselves. The CIOT talks in its submission to HMRC about “the erosion of the principles of a fair justice system…” The ICAEW says the proposals are “fundamentally flawed...”

Ingenious has been trying to obtain a definitive ruling on the tax status of its film and games partnerships for many years. The company requested a hearing before the tax tribunal in 2011 to resolve this matter as expeditiously as possible, but HMRC has repeatedly used stalling tactics to delay a hearing.

Ingenious is proud of its record in financing hit films, including Avatar, Life of Pi and The Best Exotic Marigold Hotel, which have generated more than £1bn of taxable revenue for the UK Treasury, with a further £1 billion of taxable revenue expected over the life of the films.

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