This webinar provides a practical perspective on the HMRC versus BlackRock case, focusing on the legal aspects of group structure design and intercompany agreements for multinational corporations. We discuss the relevance of legal theory in transfer price decisions and how it impacts international taxation. Understanding these court cases is crucial for effective tax planning and intercompany accounting.
Why intercompany agreements fall through the cracks between legal and transfer pricing teams, and how a proactive, cross-functional approach keeps a group audit-ready — from spotting gaps to defending your position during an audit.
A short case law briefing on HMRC v BlackRock: the fact pattern, HMRC’s challenge on transfer pricing and unallowable purpose, and how the courts approached covenants, security and control — plus what it all means for groups managing intercompany loans.
This webinar focussed on the legal implementation of limited risk arrangements in transfer pricing.