Episode 2: HMRC v BlackRock: what should we learn?

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.