Royal Bank of Canada v Revenue and Customs (Corporation Tax – Oil Royalties Received By Overseas Bank): FTTTx 23 Jun 2020

Corporation tax – oil royalties received by overseas bank and applied to outstanding debt of insolvent oil exploration borrower – whether bank’s rights amounted to ‘immovable property’ under UK/Canada double tax treaty Article 6(2) – whether royalty payments subject to corporation tax as ring fence profits of deemed UK permanent establishment under s 1313 CTA09 – whether certain discovery assessments invalid – appeal dismissed

[2020] UKFTT 267 (TC)
Bailii
England and Wales

Corporation Tax

Updated: 26 January 2022; Ref: scu.652732