UT rules on the UK-Canada Double Tax Treaty

Michael Ripley 11 New Square

In a decision recently released , the UT has decided that payments received by the Royal Bank of Canada are subject to tax under the UK’s “ring fence” regime. The case is the first in the UK to consider the scope of taxing rights under the immovable property article of a double tax treaty.


Michael Ripley acted for HMRC, led by Jonathan Bremner QC

Jonathan Peacock QC and Sarah Black acted for Royal Bank of Canada


The decision can be found here.