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...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.


  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!

TRY LAW360 FREE FOR SEVEN DAYS

Attached Documents

Related Sections

Law Firms

Companies

Government Agencies

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!