This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
examines the Court of Appeal decisions in BlackRock and Hargreaves
Property, HMRC’s updated guidance on capital-raising arrangements and
share exchange clearances, and the OECD’s consolidated commentary on the
GloBE model rules.
BlackRock: transfer pricing and unallowable purpose
In BlackRock Holdco 5 LLC v HMRC [2024] EWCA Civ 330 the Court of Appeal had to consider whether loan relationship debits were restricted by the application of the transfer pricing rules in TIOPA 2010 Part 4 or under the unallowable purpose rule in CTA 2009 s 441. The loan relationship came about as part of the funding structure for the acquisition of a US business by a US group. BlackRock Holdco 5 LLC (LLC 5) was a Delaware incorporated but UK tax resident LLC interposed in the structure in order to get interest deductions in...
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:
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
examines the Court of Appeal decisions in BlackRock and Hargreaves
Property, HMRC’s updated guidance on capital-raising arrangements and
share exchange clearances, and the OECD’s consolidated commentary on the
GloBE model rules.
BlackRock: transfer pricing and unallowable purpose
In BlackRock Holdco 5 LLC v HMRC [2024] EWCA Civ 330 the Court of Appeal had to consider whether loan relationship debits were restricted by the application of the transfer pricing rules in TIOPA 2010 Part 4 or under the unallowable purpose rule in CTA 2009 s 441. The loan relationship came about as part of the funding structure for the acquisition of a US business by a US group. BlackRock Holdco 5 LLC (LLC 5) was a Delaware incorporated but UK tax resident LLC interposed in the structure in order to get interest deductions in...
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:
