Nicholas U Jin is a trainee solicitor in Sullivan & Cromwell’s London office advising on general U.K. corporate tax matters.
Nicholas U JIN
Trainee solicitor, Sullivan & Cromwell LLP
Trainee solicitor, Sullivan & Cromwell LLP
Nicholas U Jin is a trainee solicitor in Sullivan & Cromwell’s London office advising on general U.K. corporate tax matters.
Royaume-Uni - Transfer pricing - Tax advantage main purpose and apportionment - The Court of Appeal has held that the transfer pricing rules do not require companies to include unnecessary covenants in intra-group loans, overturning an Upper Tribunal decision on this point; it agreed with the UT, however, that tax deductions for the interest on the loans in question should be disallowed under the unallowable purposes rule.
BlackRock Holdco 5, LLC v HMRC [2024] EWCA Civ 330, 11 avr. 2024