The UK Government recently published a 19 July 2022 decision of the Upper Tribunal regarding the deduction of interest on an intragroup loan, which addresses a transfer pricing issue and an unallowable purpose issue. The case concerned the structure used by the BlackRock group for the acquisition of the North American investment management business of Barclays Global Investors from Barclays Bank plc in December 2009. The ultimate issue in the case was whether the Respondent, BlackRock Holdco 5, LLC (LLC5), which was created and used as part of the acquisition structure, was entitled to non-trading loan relationship debits (deductions) in...