The tax avoider

An accountant’s cunning scheme to multiply his client’s tax relief with a cinematic investment gradually unspools…


“Film? You’re suggesting I put money into… a film?” Eustace Harker – native of Windsor, domiciled in Antigua, resident (for 182 days a year) of a property on The Bishops Avenue – leaned forward in the black leather chair of his accountant’s offices in Mayfair, and frowned. His lanky frame, from John Lobb shoes to dark-blond hair, formed an awkward series of hairpins. He looked like an eel folded up in haste.

“The government is keen to encourage investment in our, ah, thriving film industry,” said the accountant. “Naturally, as an investor you’d be able to claim tax relief on your contribution. But also, by a strange quirk, you can claim on the contributions of your co-investors. Say you put in £0.5m and they put in another £1m, you claim on the whole £1.5m.”

Harker wasn’t a details man. He left that to the little people. His specialities were attending school reunions, schmoozing Middle Eastern clients and irritating wine waiters. But he understood simple arithmetic. A look of cautious welcome took up residence on his face.

“As it happens,” the accountant continued, producing a Manila folder from the second drawer of the desk, “we have a promising project in need of backers. Fits the bill admirably. A young arthouse director, a talented cast…” He opened the folder and pushed it across the desk. The client peered at it sideways.

Crazy Banana?” asked Harker, his frown returning as he pulled the sheaf of documents towards him. But as he thumbed through them, his facial muscles visibly relaxed into piqued interest.

“This is, ahem, somewhat irregular,” said producer Ben Brand, a few months later, as he fiddled with his rimless glasses while trailing Harker – for the third day running – across the east London set of Crazy Banana. “Usually, our investors are content to operate at arm’s length from the actual production. Artistic independence is very…”

“Capital, capital,” said Harker, who had heard the phrase used in a film and taken rather a shine to it. At that moment, the film’s 22-year-old star, Alina Clemenceau, emerged from her dressing room.My dear,” exclaimed Harker, with a florid and hideous bow. “How are you?”

“Awright, Eustace?” chirped Alina.


A year and a half later, Harker’s enthusiasm for the UK film industry – and his paternal interest in the career of Alina Clemenceau (née Sally Boggis) – continued unabated. Indeed, as his advisers frequently reminded him, the amount of time he spent supervising his investment was putting his non-domiciled status in a grey area, tax-wise.

Most industry observers – or rather those who had taken any interest at all – did not predict great things for Crazy Banana. The larger cinema chains hadn’t scrabbled to snap up this “irreverent British comedy – natural hier [sic] to Four Weddings and a Funeral”, and it was only at the insistence of its chief backer that it would be having a premiere. A suitable cinema – owned by a friend of a friend – had been lined up in Richmond.

But there was a problem: Harker had already spent 182 days in the UK this tax year. His accountant, his tax lawyer and Mrs Harker all pressed on him the importance of a nice, long summer holiday in Antigua. But art came before commerce. “I’m going,” he announced. “Got to be done. Got to be done. On such a night as this did fiery Adonais – er…”

It so happened, fate being what it is, that the premiere of Crazy Banana took place the day after news broke of the closure of what the Mail on Sunday called a “£2bn film tax loophole”. There were also reports of the ink just drying on some substantial back-tax demands. Harker seemed barely to notice.

The rugger-enthusiast-turned-cineaste was still beaming on the threadbare red carpet, elbow inadvertently occluding his protegée’s face, when a call came. “I’ve just spoken to the Revenue,” said his accountant. “The government is applying to have you declared resident in the UK. You’ve been here 183 days and I’m powerless…”

“Eh?” said Harker.

“The tax implications are…”

Harker shrugged. He was feeling – stoical? Was that the word? He showed more teeth to the man from the Richmond and Twickenham Times and scooped his fringe off his face with a big hand. “Ars longa, vita nuova and all that.”


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