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.