Court of Appeal ruling in favour of the Royal Bank of Canada.

The Court of Appeal has ruled in favour of the Royal Bank of Canada in its long-running dispute with HMRC about the application of the “income from land” article of the UK/Canada Double Tax Treaty to loan repayments made to RBC.  The case is significant both as regards the income from land article but also the cross-border treatment of payments related to oil receipts.

Jonathan Peacock KC and Sarah Black acted for RBC (Appellant) and were instructed by Norton Rose Fulbright.

Jonathan Bremner KC and Michael Ripley acted for HMRC (Respondent).

The decision can be found here.