Income Tax Act 2007 section 82

Exploitation of films

Section 82 directs individuals who trade in the exploitation of films to specific provisions that restrict loss relief and impose additional tax charges.

• This section applies to any individual carrying on a trade that consists of or includes the exploitation of films
• Where the film trade is carried on in partnership, section 115 restricts the availability of sideways relief for losses
• Where the individual claims sideways relief for a loss from the film trade — whether carried on alone or in partnership — section 796 may impose an income tax charge
• The section acts as a signpost to anti-avoidance rules rather than imposing restrictions directly