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
Published 17 February 2022