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Loans › Transfer Pricing

White & Case LLP

Important Tax Update: Luxembourg Court Decision on Interest Free Loans and Debt to Equity Ratio – A Global Impact

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International transactions, such as private equity deals, mergers and acquisitions, and financing arrangements, frequently leverage Luxembourg entities as holding companies or joint ventures. It is common for such companies...more

Proskauer Rose LLP

UK Tax Round Up - April 2024

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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

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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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