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Film partnerships on cutting room floor?

Budget plans to scrap section 48 relief for low-budget British films could bring down the curtain on most film partnership schemes.

Wednesday&#39s Budget confirmed that section 48 – which allows investors to write off the whole of their investment under certain conditions – is likely to be ditched next July and replaced with a tax credit scheme for production expenditure.

The new relief, which will cover 20 per cent of the production costs of British films, will go direct to the film-maker and not to any third party.

The move has been criticised by film partnership providers which had pinned their hopes on the Government reversing a decision that they believe will drastically limit availability of the schemes for higher-rate taxpayers.

They claim the few schemes on offer will be far less attractive to investors who often buy into them every year.

The Government, which is reviewing the treatment of co-productions with a view to tightening the definition of which films qualify for scheme partnerships, is not publishing full details of the new relief until the summer.

However, it is considering whether it can increase the proportion of British films getting distribution.

In his Budget speech on Wednesday, Brown said he was motivated to make the change because a minority in the film industry has been abusing the available reliefs.

Teather & Greenwood tax-efficient solutions executive Tom Hulme says: “What it is suggesting is a totally different process. It is very unclear but removing section 48 could potentially sound the death knell for schemes. There will be some around but they will be far less attractive.”

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