Film Scheme Tax Partnerships – Investor Claims
FS Litigation’s Track Record in Film Scheme Disputes
If you were advised to invest in a film partnership scheme — including Eclipse, Ingenious, Scion, Icebreaker, or similar — and are now facing tax demands, we may be able to help.
This includes individuals who:
- Received Accelerated Payment Notices (APNs) or Partner Payment Notices (PPNs)
- Are being chased by HMRC years after investing
- Were advised by accountants or IFAs with a conflict of interest (commission payments)
- Were not properly warned about the risks of the scheme
FS Litigation’s specialist tax litigation team was one of the first to represent investors involved in high-profile film partnership tax schemes, including Eclipse Film Partners, Scion, Icebreaker, Ingenious, and others.
These schemes were promoted as legitimate tax mitigation opportunities but have since been successfully challenged by HMRC, exposing investors to significant and unexpected tax liabilities.
We have successfully pursued claims against financial, tax and accountancy advisers who failed to adequately explain the risks or carry out proper due diligence or those who received an undisclosed commission or introducer fee.
Many investors don’t realise that time limits may soon prevent them from bringing a legal claim — even if the tax dispute is ongoing.
Contacting us now allows us to assess the limitation period and take urgent steps to preserve your right to claim.
How the Scheme Worked
Film partnership tax schemes were designed to generate tax relief for high-net-worth individuals by investing in UK film production.
Investors were advised that they could claim large tax deductions on the back of borrowing and partnership losses. However, HMRC has challenged these schemes as being non-trading or abusive, particularly following the Eclipse 35 litigation.
Investors have since faced large tax bills, often with added interest and penalties, many years after the schemes were entered into. Many of the advisers who recommended film schemes failed to explain the risks, overstated the likelihood of success, or did not conduct proper due diligence.
HMRC’s Response
The ruling in Eclipse 35 marked a turning point in HMRC’s approach to these schemes. HMRC has since pursued investors with Accelerated Payment Notices (APNs), Partner Payment Notices (PPNs), and direct tax demands.
FS Litigation has a wealth of experience assisting clients at all stages of the HMRC process — from enquiries and settlement discussions to tribunal appeals and judicial review applications.
As of 2025, HMRC continues to issue settlement demands and notices in relation to historic film partnership schemes, including Eclipse and Ingenious. New claims are being brought against financial and tax advisers — particularly where commission payments were not disclosed. Professional bodies have emphasised that duty-of-care obligations remain actionable, and insurers remain exposed. FS Litigation is actively advising clients in this space.
FS Litigation’s Expertise
FS Litigation remains one of the UK’s leading law firms in professional negligence claims arising out of failed tax avoidance schemes. We have successfully recovered multi-million-pound settlements for individuals affected by Eclipse, Ingenious, Icebreaker and similar schemes.
We are ranked Band 1 by Chambers & Partners and recognised by The Legal 500 for our high-value tax and professional negligence litigation.
Chambers & Partners: “The team is especially skilled acting on high-value tax-related disputes.”
Legal 500: “FS Litigation has a national reputation for high-profile, multi-million pound ‘big ticket’ litigation... its team is the envy of many of the top law firms it comes up against.”
Our lawyers are regularly quoted by the Financial Times, The Times, and Citywire. We have worked with the BBC and Channel 4 on investigations into mis-sold tax schemes.
We also work with major accountancy firms whose clients require specialist representation against former tax advisers and with HMRC.
Representative Cases
FS Litigation led one of the UK’s first reported multi-million-pound tax negligence claims involving film schemes — a £6M dispute brought before the courts against accountants and tax advisers.
We have also successfully challenged HMRC action through judicial review, including blocking bankruptcy proceedings for scheme participants.
What Should You Do?
Many investors are still dealing with the financial and emotional fallout of these schemes years later — facing demands from HMRC or being unable to move on while a threat of litigation or bankruptcy hangs over them.
If this applies to you, it’s important to know you’re not alone — and that redress may still be possible.
If you think your adviser may have received an undisclosed commission for recommending a film scheme to you, you should take legal advice as swiftly as possible. You may still be able to recover all losses arising from the film scheme.
We offer a free, confidential consultation to assess your claim and can notify your former adviser to preserve any insurance cover.
Funding Options
FS Litigation acts under no-win, no-fee agreements in the majority of its tax negligence work. We also work with litigation funders and brokers to secure ATE insurance (if required) and mitigate financial exposure.
Contact Us
To speak confidentially with a member of our team, please contact us or call us on 0161 714 4520