Double Taxation, Financial institutions, Income categorization, International Tax Law, MNE Profits, OECD, Permanent Establishments, Royalties, Tax Treaties, United Kingdom
Income from immoveable property: Article 6 and royalty streams
Following the Supreme Court decision in Fowler v HMRC [2020] UKSC 22, the UK First-tier Tribunal has considered another case where classification of a source of income for tax treaty purposes was in issue. This time the question was classification as business profit or income from immovable property in the Canada-UK double tax treaty. In…