Royal Bank of Canada v Revenue and Customs: UTTC 17 Feb 2022

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

Citations:

[2022] UKUT 45 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 27 August 2022; Ref: scu.677616