This week's videos deal with the UK Upper Tier Tribunal decision in the BlackRock case in 2022. Here, BlackRock in the US acquired assets from Barclays in the US. It did so through a hybrid US LLC tax resident in the UK. BlackRock got denied an interest deduction of more than USD 1 billion in the UK, which, though paid to the US was not subject to tax in the US.
BlackRock's plan was to use the interest deductions in the UK to erode the taxable income of other UK BlackRock entities.
The structure was set up before the OECD BEPS initiative.
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BlackRock Upper Tier Tribunal [ Ссылка ]
BlackRock First Tier Tribunal [ Ссылка ]
