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Loans International Tax Issues

Cadwalader, Wickersham & Taft LLP

Brakes Applied to a Speedy Reorganisation

The Upper tax tribunal (“Upper Tribunal”) has confirmed the decision of the First-tier tax tribunal (“FTT”), delivered in 2021, in the case of Kwik-Fit Group Limited and others v HMRC. This decision of the Upper Tribunal...more

Cadwalader, Wickersham & Taft LLP

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

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

Katten Muchin Rosenman LLP

LSTA Publishes Revised Documents Effective April 24, 2014

The Loan Syndications and Trading Association (LSTA) has released new forms of its primary trading documents, effective for trades entered into on or after April 24, 2014. The LSTA's updated forms are primarily...more

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