Double Taxation Relief: France: alterations to the amount of relief
Regulation 11 of SI2012/458
If the amount of the French bank levy changes, then there will be a subsequent knock-on effect on the amount that can be claimed as relief in the UK. When this happens the responsible member or relevant entity will need to recalculate the amount of relief due and amend the claim.
It must also do this if the actual amount of the French bank levy stays the same but a person receives a payment from the French authorities in respect of the French bank levy.
However it does not apply where the French authorities make a payment because the French bank levy is tax deductible in France, for example the French bank levy paid increases a loss which leads to a tax repayment. This is not within the scope of Regulation 11.
Regulation 13 of SI2012/458
Where the amount of the French bank levy or the bank levy against which relief is claimed is altered then, provided a claim has already been made for double taxation relief, the claim or assessment may be revised for up to 6 years from when all material determinations have been made.
Regulation 14 of SI2012/458
Where the amount of relief becomes excessive the responsible member or relevant entity must inform HMRC within 12 months of the adjustment to the French bank levy.