In HMRC v BlackRock Holdco 5, LLC [2022] UKUT 00199, the Upper Tribunal (UT) held that loan relationship debits claimed as part of an intra-group financing arrangement were wholly attributable to the unallowable purpose of the lending and not the commercial purpose and were denied.

The UT found that:

The UT allowed the appeal on both counts and the deduction of the NTLR debits was denied.

Useful guides on this topic

Loan Relationships
How are loans made to and by a company taxed? What are the rules when loans are written down? What is the difference between a trading and non-trading loan relationship? What are the rules for connected party loans? 

Loan relationships toolkit: Is a balance within the rules?
When does a balance fall within the loan relationship rules?

Losses: Trading and other losses
When can a company offset its losses? What restrictions are there? How are loss claims made?

External link

HMRC v BlackRock Holdco 5, LLC [2022] UKUT 00199


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