HMRC v BlackRock Holdco 5 LLC: transfer pricing and unallowable purpose

Case comment by Mike Lane on the Upper Tribunal decision 

The Upper Tribunal decision in HMRC v BlackRock Holdco 5 LLC is of particular interest as a rare instance of a case involving the application of the UK’s transfer pricing legislation as well as being the first Upper Tribunal case on how to apply the just and reasonable apportionment provision in the loan relationships unallowable purpose rule.

      This material was first published by Thomson Reuters, trading as Sweet & Maxwell, 5 Canada Square, Canary Wharf, London, E14 5AQ, in the British Tax Review as “HMRC v BlackRock Holdco 5 LLC: transfer pricing and unallowable purpose” [2022] B.T.R. 496 and is reproduced by agreement with the publishers.