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United Kingdom Upper Tribunal (Tax and Chancery Chamber)
You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Royal Bank of Canada v Revenue and Customs [2022] UKUT 45 (TCC) (17 February 2022)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2022/45.html
Cite as: [2022] STC 406, 24 ITL Rep 529, [2022] UKUT 45 (TCC), [2022] STI 310, [2022] BTC 505
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Royal Bank of Canada v Revenue and Customs [2022] UKUT 45 (TCC) (17 February 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
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