The scheme was marketed by Goldcrest Pictures Limited, which has financed, produced or distributed over 100 films, including Margaret Thatcher biopic The Iron Lady.
According to HM Revenue and Customs (HMRC), a Goldcrest company, based in the British Virgin Islands, sold rights in two feature films for an artificially inflated figure of £21.9 million to hedge fund manager Patrick Degorce.
He was only required to pay £4.8 million of his own money, and immediately sold the rights back to the same Goldcrest company for a fraction of the price. He claimed the difference was a trading loss, and aimed to set this off against £18.8 million profits from his hedge fund to avoid paying tax on them.
An HMRC spokesman said the tribunal, sitting in London, ruled the scheme did not work and users would receive no tax relief on the money they put into it.
David Gauke, Exchequer Secretary to the Treasury, said: "The Government has made it clear that we will not allow marketed avoidance schemes to deprive the UK of vital tax revenues. We have invested nearly £1 billion to help HMRC take action against the minority of taxpayers who think they are above the law, we are bringing in new anti-avoidance legislation and we are giving HMRC greater powers to clamp down on those who sell dubious avoidance schemes like this one.
Jim Harra, HMRC director general for business tax, said: "This is another film scheme which has delivered none of the tax benefits promised by the promoter.
"Mr Degorce put in nearly £5 million of his own money, including £1.6 million which went into the promoter's pocket, but all he has come away with is an HMRC inquiry and an appearance before a tax tribunal.
"Sadly, many people have been tempted by similar schemes which we also believe don't work, and we have opened a settlement opportunity to get them back on the straight and narrow. I would urge anyone in this position to sign up for this facility quickly."