HMRC successfully defends assessments of oil royalties

HMRC has successfully defended substantial corporation tax assessments on oil royalties in Royal Bank of Canada v HMRC [2020] UKFTT 267 (TC), an important decision by the First-tier Tribunal (Tax Chamber) on the construction of article 6 of the UK / Canada double tax treaty (immovable property) and the scope of the UK’s ring fence corporation tax regime.

Related briefings

Recent Commercial Court decision highlights the importance of strict compliance with claim notification provisions in share and business sale and purchase agreements

In a recently delivered decision, Dodika Limited & Others v. United Luck Group Holdings Limited [2020] EWHC 2101 (Comm), Mr Peter MacDonald Eggers QC (sitting as a Deputy Judge of the Commercial Court) has ruled that a notice of claim under a tax covenant contained in a share sale and purchase agreement (SPA) failed to comply with the requirements of the claim notification provisions in the SPA. As a result, a sum of USD 50 million held in escrow was liable to be released to the SPA sellers.

Commercial Court upholds order enforcing arbitration award against public policy challenge under s 103(3) Arbitration Act 1996

Commercial Court upholds order enforcing arbitration award against public policy challenge under s 103(3) Arbitration Act 1996: Alexander Brothers Ltd v Alstom Transport SA and Anr [2020] EWHC 1584 (Comm). The Defendants applied to set aside an order enforcing a Swiss-seated ICC arbitration award in favour of the Claimant on the public policy ground. The […]

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Permission in principle – growth, renewal, protect

The biggest shake up of the planning system since 1947 continues apace with the announcement, on 2 August, of government plans to create an automatic green light for development within specifically designated areas of the country.

Setting aside company transactions involving Jersey, Guernsey and BVI companies

Financial pressure can change perspectives on transactions – whether through the lens of an insolvent winding up, in the context of a counterparty or related interested party exploring ways in which they might unravel a transaction, or a new board considering whether a company can extricate itself from contractual arrangements that appear to have been subject to a conflict of interest or which were for an improper purpose.

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