In Royal Bank of Canada, the Court of Appeal overturns the Upper Tribunal’s decision and holds that the Canadian bank is not subject to UK tax on contractual payments relating to the production and price of UK oil which it had received pursuant to the receivership of a debtor. The consultation on reforms of the legislation on transfer pricing, permanent establishment and diverted profits tax is published for comments until 14 August. The Court of Appeal in Civic Environmental Systems Ltdconsiders the effect of an increase in prior period profits, following an HMRC enquiry, on a claim for loss carry back. HMRC issues partial draft guidance on the multinational top-up tax covering the scope of the rules and administrative provisions with more draft guidance to follow.
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In Royal Bank of Canada, the Court of Appeal overturns the Upper Tribunal’s decision and holds that the Canadian bank is not subject to UK tax on contractual payments relating to the production and price of UK oil which it had received pursuant to the receivership of a debtor. The consultation on reforms of the legislation on transfer pricing, permanent establishment and diverted profits tax is published for comments until 14 August. The Court of Appeal in Civic Environmental Systems Ltdconsiders the effect of an increase in prior period profits, following an HMRC enquiry, on a claim for loss carry back. HMRC issues partial draft guidance on the multinational top-up tax covering the scope of the rules and administrative provisions with more draft guidance to follow.
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