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The Upper Tribunal judgment in BlackRock Holdco 5, LLC—important issues raised on unallowable purpose and transfer pricing

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Published on: 15 September 2022
Published by a LexisNexis Tax expert

Table of contents

  • Facts and issues
  • Transfer-pricing
  • Unallowable purpose
  • Conclusion
  • Case details

Article summary

Tax analysis: In this article, Constantine Christofi of RPC reviews the Upper Tribunal (UT) judgment in HMRC v BlackRock Holdco 5 LLC.

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Jurisdiction(s):
United Kingdom

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