Re: Hollywood FC
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Don't the know the answer to that one specifically, but HMRC have a general anti abuse rule they can apply to any tax avoidance where the main reason for a transaction or scheme is to avoid tax and little commercial reason. So it's difficult to "get away with" any sort of tax avoidance planning now, as whilst it's not illegal as such, it will generally fail, plus you have a duty to tell them of the tax avoidance you came up with so they can they counter it!
There probably is therefore a level they deem commercially reasonable to have as image rights before it becomes a tax avoidance scheme.
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