In HMRC v BlackRock Holdco 5 LLC [2022] UKUT 199 (TCC) the Upper Tribunal (UT) overturned the decision of the First-tier Tribunal (FTT) in relation to the deductibility of interest payable on $4bn worth of loan notes. The loan notes were part of intra-group financing for a third-party corporate acquisition. The UT ultimately denied the interest deduction.
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