In 2022, the UK Upper Tribunal’s judgment in HMRC v BlackRock sparked a lot of comment – and not a little consternation – around the transfer pricing community. LCN co-founder Paul Sutton discusses the implications in detail.
- How the case changes things, and how it doesn’t
- How the Upper Tribunal’s position differed from the previous First-tier Tribunal judgment
- The most important implications for MNEs and their transfer pricing advisers.
