HM Revenue and Customs v. BlackRock
HM Revenue and Customs v. BlackRock
Jurisdiction
United Kingdom, Upper Tribunal (UT)
Summary of Facts
HMRC disputed BlackRock’s inter-company loan arrangements following its acquisition of Barclays Global Investors, challenging the arm’s length nature of the loan interest rates.
Key Issues
Whether the interest rates on inter-company loans were compliant with the arm’s length principle.
Decision and Reasoning
The UT ruled in favor of HMRC, confirming the denial of shareholder loan interest deductions involving $4 billion in loans.
Importance and Implications
This case underscores the importance of ensuring that inter-company financial arrangements are consistent with the arm’s length standard to avoid tax adjustments.
