FTT concludes bank carries on a North Sea oil extraction trade

The FTT has handed down its decision (heard June 2019) in Royal Bank of Canada v HMRC [2020] UKFTT in which it has concluded, applying Article 6 of the UK: Canada Double Tax Treaty, that RBC carried on a North Sea oil extraction trade when it received royalties computed by reference to the price of oil from the Buchan Field.  The decision addresses the scope of Article 6 and the application of the UK corporation tax provisions charging tax on North Sea oil extraction activities.

Jonathan Peacock QC and Sarah Black acted for RBC.