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3 March 2023

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

Paul Sutton and Paul O’Regan discuss the 2022 UK case HMRC v BlackRock. The Upper Tribunal’s judgment, concerning the deductibility of interest on a $4bn intra-group loan, has forced transfer pricing professionals to change their thinking in some areas. What exactly has changed? And what hasn’t?

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.

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