A group of investors is also suing Ingenious for the advice provided in setting up the scheme which involves buying film rights and using paper losses to create significant tax benefits for investors. Experts estimate the groups face an up hill battle because of the waivers they signed.
Ingenious has also hit back at HMRC’s handling of the case in the long-running legal saga, unsuccessfully seeking redress for investors.
The scheme is thought to be worth £1.2bn and now has an estimated £480m in tax owed.
An HMRC spokesperson said they were pleased to have won the case: “Tax avoidance doesn’t pay. Most schemes simply don’t work – and people can end up paying more than they were trying to avoid in their misguided attempts to save money.”