The WLR Daily case summaries
[2024] WLR(D) 159
Court of Appeal
Blackrock Holdco 5, LLC v Revenue and Customs Commissioners
[2024] EWCA Civ 330
2024 March 5, 6; April 11
Peter Jackson, Nugee, Falk LJJ
Revenue— Corporation tax— Loan relationships— Taxpayer issuing loan notes to parent company and subsequently claiming deductions of loan relationship debits in respect of interest and other expenses relating arising under loan notes for purposes of calculating corporation tax due— Whether transfer pricing provisions allowed for consideration of third parties— Whether taxpayer entitled to claim deduction for loan relationship debits— Whether loan relationship having main purpose of seeking tax advantage—
Corporation Tax Act 2009
, ss 441,42
—
Taxation (International and Other Provisions) Act 2010
, Pt 4