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HMRC internal manual

Bank Levy Manual

Double Taxation Relief: Single Resolution Fund: subject to more than one foreign levy

Regulation 15 of SI 2016/1212

As many banking groups are multi-nationals it is possible that an entity subject to the UK bank levy may also be part of a group that is subject to two or more other levies. For example a French group may own a Dutch bank which then trades in the UK via a Permanent Establishment.

The principle of home state primacy is adopted for double taxation relief for the bank levy in respect of both the French and Dutch bank levies. This means that where a foreign entity owns subsidiaries subject to the UK bank levy or trades in the UK via a Permanent Establishment the UK will give relief for any foreign levy charged upon entities that are subject to the UK bank levy.

As the Single Resolution Fund levy does not operate on a home state primacy basis, the effect of Regulation 15 will be that if credit is due against the UK bank levy for any foreign levies then relief will be given for home state primacy levies first, and then only for the Single Resolution Fund levy once these levies have been relieved.

The order for relief is set out in Regulation 15 of SI 2016/1212.