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.