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View all AlliancesHelping clients meet their business challenges begins with an in-depth understanding of the industries in which they work. That’s why KPMG LLP established its industry-driven structure. In fact, KPMG LLP was the first of the Big Four firms to organize itself along the same industry lines as clients.
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Learn morePayments not subject to corporation tax under treaty, but subject to “ring fence” taxation
The Supreme Court held that payments by a UK entity to a Canadian bank based on production from an oil field on the UK contingent shelf were not subject to UK corporation tax under the UK-Canada income tax treaty.
The court concluded that the payments did not constitute a “right to work” the oil field and, even if they had, were not “consideration” for those rights.
However, the court concluded that because the payments were based on both the volume and price of oil, they were subject to “ring fence” taxation under section 1313 of Corporation Tax Act 2009.
Read a February 2025 report prepared by the KPMG member firm in the UK
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