The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Blackrock: transfer pricing and unallowable purpose
In Blackrock Holdco 5 LLC v HMRC [2020] UKFTT 0443 (TC) HMRC disallowed the deductibility of interest on $4bn worth of intra-group loans either on on the basis of the unallowable purpose rule in CTA 2009 s 441 which disallows debits in respect of a loan relationship where they are on a just and reasonable apportionment attributable to the unallowable purpose or in the alternative on the basis of transfer pricing arguing the loans would not have been made at all between independent enterprises.
The loan notes were issued as part of an acquisition funding structure for the Blackrock group. The structure comprised a chain of three Delaware LLCs. LLC 4 and LLC 6 were tax resident in the US whereas...
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The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Blackrock: transfer pricing and unallowable purpose
In Blackrock Holdco 5 LLC v HMRC [2020] UKFTT 0443 (TC) HMRC disallowed the deductibility of interest on $4bn worth of intra-group loans either on on the basis of the unallowable purpose rule in CTA 2009 s 441 which disallows debits in respect of a loan relationship where they are on a just and reasonable apportionment attributable to the unallowable purpose or in the alternative on the basis of transfer pricing arguing the loans would not have been made at all between independent enterprises.
The loan notes were issued as part of an acquisition funding structure for the Blackrock group. The structure comprised a chain of three Delaware LLCs. LLC 4 and LLC 6 were tax resident in the US whereas...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
