UK Court Revives HMRC's Case Against $4B BlackRock Loan

By Natalie Olivo (July 25, 2022, 6:07 PM EDT) -- A U.K. appeals court sided with HM Revenue & Customs in concluding that tax deductions couldn't be made on interest payments related to a $4 billion intercompany loan involving affiliates of global investment giant BlackRock Inc.

The First-tier Tribunal, Tax Chamber, erred in concluding that BlackRock Holdco 5 LLC, a British subsidiary of U.S. investment company BlackRock Holdco 4 LLC, took a $4 billion loan from its U.S. parent under arm's-length terms, according to the Upper Tribunal's July 19 judgment. Specifically, the lower tribunal — referred to as the FTT — shouldn't have taken into account hypothetical third-party agreements that were...

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