Case law briefing on HMRC v BlackRock and what it means for transfer pricing and intercompany financing.
This session walks through the key facts, the court decisions, and the practical implications for groups managing intercompany loans and agreements.
What’s covered:
- The fact pattern behind the BlackRock structure
- HMRC’s challenge on transfer pricing and unallowable purpose
- How the courts approached covenants, security, and control
- Why the legal form of transactions matters
- Practical steps to reduce risk in intercompany financing
Key takeaway: pricing comes after the form and substance of the transaction. Get the structure wrong, and the pricing won’t save you.