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HMRC internal manual

Banking Manual

Banking surcharge: calculation of surcharge profits: banking company liable to a CFC charge


If a banking company is liable to a CFC charge, the appropriate rate to be applied in calculating the CFC charge is the total of the UK main rate and the rate for the surcharge.   

Where a banking company is subject to a CFC charge, the amount at step 5 in section  TIOP10/S371BC(1) is to be increased by:



PCP is the percentage of the CFC’s chargeable profits allocated to the company

SASA is the amount of the chargeable company’s surcharge allowance which it chooses to allocate against the surcharge

SP is the rate of surcharge.