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HMRC internal manual

Bank Levy Manual

Double Taxation Relief: France: background

On 21 November 2010 HM Treasury announced that the UK and France had come to an understanding with regard to relieving double taxation of banks in respect of both countries’ bank levies.

The announcement also stated that the principle of ‘home state primacy’ would be used in order to give effect to relief from double charging in relation to the two countries’ bank levies.

Rules setting out how relief for the French bank levy is to be calculated and allowed against the UK bank levy are contained in The Bank Levy (Double Taxation Relief) Regulations 2012 (SI2012/458) (web) ()