In BlackRock Holdco LLC v HMRC, despite the Court of Appeal finding in favour of BlackRock Holdco 5 (LLC5) on the transfer pricing issue, its decision that the loan had an unallowable purpose means that LLC5 cannot claim deductions of £654m ([2024] EWCA Civ 330). The judgment serves as a warning about the extent of tax-advantaged structuring of otherwise genuine commercial acquisitions.