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Loans Transfer Pricing United Kingdom

Proskauer Rose LLP

UK Tax Round Up - April 2024

Proskauer Rose LLP on

Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more

Cadwalader, Wickersham & Taft LLP

HMRC v BlackRock Holdco 5 LLC Throws a Spotlight on UK Transfer Pricing and the ‘Unallowable Purposes’ Rule

A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more

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