EX-8.2 5 ex8_2.htm EXHIBIT 8.2

 

Exhibit 8.2

 

 
April 27, 2023
 
   

Royal Bank of Canada

200 Bay Street

Royal Bank Plaza

Toronto, ON M5J 2J5

 

 

 

Norton Rose Fulbright Canada llp
222 Bay Street, Suite 3000, P.O. Box 53
Toronto, Ontario  M5K 1E7 Canada

 

F: +1 416.216.3930

nortonrosefulbright.com

 

 

+1 416.216.4000

 

Dear Sirs/Mesdames:

 

Senior Global Medium-Term Notes, Series I

 

We have acted as Canadian tax counsel to Royal Bank of Canada (RBC) in connection with the issuance by RBC of its Senior Global Medium-Term Notes, Series I – U.S.$1,600,000,000 aggregate principal amount of 4.950% Senior Notes due April 25, 2025 and U.S.$900,000,000 aggregate principal amount of 5.000% Senior Notes due May 2, 2033 (collectively, the Offered Securities).

 

We hereby confirm to you that the statements of Canadian tax law set forth under the heading "Canadian Federal Income Tax Considerations" in the pricing supplements relating to the Offered Securities, each dated April 24, 2023, are our opinion and are accurate in all material respects subject to the limitations and qualifications therein.

 

We hereby consent to the filing of this opinion as an exhibit to RBC’s Report of Foreign Private Issuer on Form 6-K and to the reference to us under the heading "Canadian Federal Income Tax Considerations" in the pricing supplements referred to above. In giving such consent, we do not thereby admit that we are in the category of persons whose consent is required under Section 7 of the Securities Act of 1933.

 

Yours truly,

 

/s/ Norton Rose Fulbright Canada LLP