By Natalie Olivo (July 25, 2022, 6:07 p.m. EDT) – A UK appeals court has revived HM Revenue & Customs’ challenge to a $4 billion intercompany loan involving subsidiaries of global investment giant BlackRock Inc., finding that a court failed to properly consider whether unrelated companies would have agreed to the same transaction.
The first level court, the Tax Chamber, erred in finding that BlackRock Holdco 5 LLC, a UK subsidiary of US investment firm BlackRock Holdco 4 LLC, took out a $4 billion loan from its company American mother on arm’s length terms, according to the Upper Tribunal’s Judgment of July 19. Specifically, the lower court – called FTT – should not have considered hypothetical…
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