Supreme Court success for the Royal Bank of Canada in Tax Treaty case

The Supreme Court has ruled in favour of the Royal Bank of Canada in the last instalment of this 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 (Respondent) and were instructed by Norton Rose Fulbright.

Kevin Prosser KC and Michael Ripley acted for HMRC (Appellants).

The decision can be found here and the Supreme Court press summary here.