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HMRC internal manual

Bank Levy Manual

Double Taxation Relief: Single Resolution Fund: background

From 1 January 2015 all EU Member States have been bound by the Bank and Resolution Directive (BRRD). One of the key elements of the BRRD is the establishment of a new levy in many EU states to fund an EU Single Resolution Fund.

The UK is satisfying its obligations under the Directive by raising contributions through its existing bank levy. However in some circumstances the Single Resolution Fund levy overlaps with the UK bank levy and gives rise to instances of double taxation.
On 8 July, as part of the Summer Budget banking tax reform, HM Treasury announced that relief would be provided against the UK bank levy for payments made to the Single Resolution Fund from 1 January 2016.

Rules setting out how relief for the Single Resolution Fund is to be calculated and allowed against the UK bank levy are contained in The Bank Levy (Double Taxation Relief) (Single Resolution Fund Levy) Regulations 2016 which can be viewed at