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HMRC internal manual

Bank Levy Manual

From
HM Revenue & Customs
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Anti-avoidance: relevant arrangements that can be ignored when applying the anti-avoidance rule: increases in excluded equity and liabilities

Paragraph 47(7) of Schedule 19

The anti-avoidance rule does not apply to relevant arrangements, so far as their effect is to increase, on an ongoing basis, excluded equity and liabilities.

Whether an increase is on an ongoing basis will be considered in the context of the bank or group’s overall funding profile over a period of time. ‘Window dressing’ to achieve a short term effect around the balance sheet date will not generally be considered to be on an ongoing basis.

Other effects of relevant arrangements are not ignored, unless an exception applies - see BKLM641000.