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HMRC internal manual

Bank Levy Manual

Collection and management: payment through the Corporation Tax system: joint and several liability

Paragraph 53 of Schedule 19

Where the bank levy is charged in relation to a group, responsibility for payment of the bank levy rests with the responsible member.

However, paragraph 53 provides that all members of the relevant group as set out in paragraph 53(3) are jointly and severally liable for the bank levy liability of the responsible member for an accounting period.

For a banking or building society group this will mean all members of the relevant group within the charge to Corporation Tax at the end of the chargeable period will be joint and severally liable.

For a relevant non-banking group, the members who will be joint and severally liable are:

  • members of any UK banking sub-group
  • any UK resident banks within the group
  • any foreign banks within the group trading in the UK through a permanent establishment.

However, for both banking groups and relevant non-banking groups there are two notable exceptions. These are set out in BKLM433100.