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HMRC internal manual

Banking Manual

Banking surcharge: surcharge allowance: introduction

CTA2010/S269DE

There is an annual allowance of £25m available to groups or, where a group has only one banking company or the banking company is not in a group, to that banking company alone.  The allowance exempts surcharge profits or CFC profits apportioned to a banking company from liability to the surcharge.  Any unused allowance cannot be carried forward.

BKM402900 provides the definition of a group for the purpose of the banking surcharge and examples of how this applies where a company leaves a group.

A banking company can choose how much of its allowance should be used as a surcharge allowance against its surcharge profits and how much should be taken into account in its calculation of any CFC charge for the period.  This information must be included in the banking company’s tax return and the total must not exceed its available allowance.

Where the total exceeds the banking company’s available allowance HMRC can take action to clawback the excess (BKM404850).

See BKM404200 for guidance on how to determine the surcharge allowance where a banking company is not in a group or is the only banking company in the group throughout the company’s chargeable accounting period

See BKM404300 for guidance on how to determine the surcharge allowance where a banking company is in a group containing more than one banking company for any part of the company’s chargeable accounting period.