North Sea

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English may be the lingua franca of our time, but it is not the only language of international law. Royal Bank of Canada v HMRC [2022] UKUT 45 (TCC).  raised issues around the interpretation of a tax…

When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain…