The Upper Tribunal decision in Royal Bank of Canada and the government’s response to the review of the UK funds regime are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
RBC: UK corporation tax on payments received by Canadian bank following receivership of debtor
In Royal Bank of Canada v HMRC [2022] UKUT 45 (TCC) the Upper Tribunal (UT) confirmed the decision of the First-tier Tribunal (FTT) that the Canadian bank RBC is subject to UK corporation tax on payments linked to an oil field. The payments had been assigned to RBC during the receivership of a Canadian debtor.
RBC had advanced a loan to Sulpetro a Canadian company which together with its UK subsidiary carried on oil exploration/exploitation activities in the Buchan Field within the UK continental shelf. At the time when Sulpetro went into...
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The Upper Tribunal decision in Royal Bank of Canada and the government’s response to the review of the UK funds regime are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
RBC: UK corporation tax on payments received by Canadian bank following receivership of debtor
In Royal Bank of Canada v HMRC [2022] UKUT 45 (TCC) the Upper Tribunal (UT) confirmed the decision of the First-tier Tribunal (FTT) that the Canadian bank RBC is subject to UK corporation tax on payments linked to an oil field. The payments had been assigned to RBC during the receivership of a Canadian debtor.
RBC had advanced a loan to Sulpetro a Canadian company which together with its UK subsidiary carried on oil exploration/exploitation activities in the Buchan Field within the UK continental shelf. At the time when Sulpetro went into...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
