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White & Case LLP

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

White & Case LLP on

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

Cadwalader, Wickersham & Taft LLP

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

Cadwalader, Wickersham & Taft LLP on

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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