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Decision summary
Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2 -- summary under Article 6
Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 an oil and gas royalty is not income from immovable property under the Canada-U.K. ... In concluding on this issue, she stated (at para. 97): … RBC does not hold, and indeed has never held, an interest in the Buchan field. ...