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UK Upper Tribunal Addresses Transfer Pricing and Unallowable Purpose Issues in BlackRock Intragroup Loan

|Approved Changes|United Kingdom
United Kingdom

The UK Government recently published a 19 July 2022 decision of the Upper Tribunal regarding the deduction of interest on an intragroup loan, which addresses a transfer pricing issue and an unallowable purpose issue. The case concerned the structure used by the BlackRock group for the acquisition of the North American investment management business of Barclays Global Investors from Barclays Ba…

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