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Tax and the City review for March 2022

Speed read
In Royal Bank of Canada, the Upper Tribunal confirms the Canadian bank is subject to UK corporation tax on payments relating to UK oil which it had received pursuant to the receivership of a debtor. HM Treasury publishes a summary of responses to the call for input on the review of the UK funds regime. HMRC updates its guidance on the meaning of ‘substantial’ in light of the decision of the Upper Tribunal in Allam criticising the previous guidance as being too narrow. The Upper Tribunal confirms the interpretation of the UK’s VAT grouping provisions in the HSBC case.
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