A group of celebrities and sports stars including David Beckham (pictured) are facing a £520 million tax bill.
According to the Financial Times, Ingenious Media has issued a warning to some 1,300 investors in its film investment scheme.
The investors, which also include Andrew Lloyd Webber, the Bank of England’s Clara Furse, Bob Geldof and Gary Lineker, each paid a minimum £100,000 to invest in the Ingenious Film Partners 2 LLP.
The scheme qualified for tax breaks under rules set up by the previous government and helped fund the likes of Life of Pi, Avatar and Girl with a Pearl Earring.
Under the arrangement investors were made directors of partnerships which made losses of £1.3 billion, which they offset against other income to reduce their tax bill.
However, HM Revenue & Customs (HMRC) believes the film scheme was simply set up to avoid tax as it intensified its crackdown on tax avoidance.
It is understood that HMRC has targeted similar schemes which helped investors avoid tax over the last decade.
Repayment notices are expected to be issued to investors over the next 20 months with a list of schemes impacted revealed in the next two weeks.
Ingenious told its clients the crackdown was likely to have an ‘adverse’ impact on them.
In a statement published by the FT, the firm said: ‘We have done everything we can to lobby for changes to the accelerated payment proposals as the Bill has progressed through Parliament, but without success.”
The warning is the latest twist in the HMRC long-running battle against film investment schemes and Ingenious.
In March Ingenious wrote to clients describing HMRC’s attack as ‘draconian’ and denied the schemes were established to avoid tax and said it intended to fight the case at a tax tribunal scheduled for November.
At the end of December 2012 HMRC wrote to individuals who had taken part in these schemes offering them a settlement opportunity.