Royal Bank of Canada v The Commissioners for HM Revenue and Customs [2022] UKUT 00045 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Edwin Johnson and Judge Rupert Jones on 17 February 2022
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CORPORATION TAX – income received by a Canadian bank from payments relating to oil produced by the Buchan oil field in the UK Continental Shelf – whether the UK has taxing rights as income from immovable property for the purposes of Article 6 of the UK / Canada Double Taxation Convention – whether the payments are liable to corporation tax under section 1313(2)(b) of the Corporation Tax Act 2009 as the right to benefit of exploration or exploitation activities
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Published 17 February 2022