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New Podcast episode: the most important learnings from BlackRock

Intercompany Agreements

6 March 2023

The key implications of the BlackRock judgment

In summer last year, the UK Upper Tribunal's decision in the case of HMRC v BlackRock Holdco 5 LLC caused some commotion in the Transfer Pricing community. There is still general agreement that the judgment has significant implications, but what exactly are they? Our new podcast episode explores this question in detail. (You'll find it in our Training Hub.) The discussion includes:

  • A quick summary of the case, and the key issues
  • Whether the judgment really is a gamechanger
  • How the Upper Tribunal's view differed from the First-tier Tribunal's judgment
  • The long-term consequences for TP professionals, and the most important learning points

As always, I’d be fascinated to hear your views, so please do feel free to let me know your thoughts.

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Article by
Paul Sutton
LCN Legal Co-Founder

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