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HMRC internal manual

Bank Levy Manual

Double Taxation Relief: background

Banking groups operate in many different territories some of which may also have introduced their own bank levy.

Where foreign countries have introduced bank levies, double taxation may arise on foreign subsidiaries and branches of UK banks and on the UK subsidiaries and branches of foreign banks.

A mechanism for alleviating such double taxation is therefore required and details on how this works are set out in BKLM740000.