A recent tribunal decision on whether the taxpayer had an unallowable purpose is likely to be of wide application, as Heather Self (Blick Rothenberg) explains. But was it correctly decided?
The FTT decision in BlackRock Holdco 5 LLC v HMRC [2020] UKFTT 443 (TC) was briefly reported in Tax Journal last week (13 November 2020) and it was also commented on by Mike Lane and Zoe Andrews in their ‘Tax and the City review’ in the same edition. Although the facts are complex the key question of whether the taxpayer had an unallowable purpose and if so what debits should be apportioned to that purpose is one which is likely to be of wide application.
The appellant BlackRock Holdco 5 LLC (LLC5) was a US-incorporated LLC which was UK resident for tax purposes. The use of a US entity rather than a simple UK...
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A recent tribunal decision on whether the taxpayer had an unallowable purpose is likely to be of wide application, as Heather Self (Blick Rothenberg) explains. But was it correctly decided?
The FTT decision in BlackRock Holdco 5 LLC v HMRC [2020] UKFTT 443 (TC) was briefly reported in Tax Journal last week (13 November 2020) and it was also commented on by Mike Lane and Zoe Andrews in their ‘Tax and the City review’ in the same edition. Although the facts are complex the key question of whether the taxpayer had an unallowable purpose and if so what debits should be apportioned to that purpose is one which is likely to be of wide application.
The appellant BlackRock Holdco 5 LLC (LLC5) was a US-incorporated LLC which was UK resident for tax purposes. The use of a US entity rather than a simple UK...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
