BlackRock's efforts to reclaim UK tax after its landmark acquisition of Barclays Global Investors have failed at the Court of Appeal, the latest instalment in a long-running dispute over the deal structure.

BlackRock swooped on Barclays Global Investors in 2009. BlackRock used $4bn in loans from one of its US group entities to buy the US part of the Barclays business, but the corporate structure of the deal also included a UK tax resident entity.