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HMRC internal manual

Bank Levy Manual

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HM Revenue & Customs
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Double Taxation Relief: equivalent foreign levy

Paragraphs 66(1)(a) and (2) of Schedule 19

The legislation at paragraph 66(1)(a) refers to double taxation relief being afforded in respect of any ‘ equivalent foreign levy’. Sub-paragraph 66(2) then explains that this means any tax imposed by the law of a foreign territory that corresponds to the bank levy.

To correspond to the UK bank levy and to be treated as an equivalent foreign levy the foreign levy must:

but

  • it will not be an equivalent foreign levy if it is a tax on income, profits or gains.