A spokesperson for HMRC said: “We are pleased that the tribunal has agreed with us that the vast majority of what was claimed in tax relief by Ingenious investors was simply not due.”
In a new ruling clarifying the original decision, tribunal judge Charles Hellier has agreed none of the tax deductions were allowable.
A controversial film-funding scheme whose celebrity investors included David Beckham, Gary Lineker and Ant and Dec has lost its latest court battle against a £700m tax bill.
The financing firm behind the scheme, Ingenious, immediately said it would appeal against the ruling.