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HMRC internal manual

Banking Manual

Banking surcharge: application to diverted profits tax

FA15/S79 & S107

Where the diverted profits of a banking company are surcharge profits or notional banking surcharge profits the applicable rate of tax payable is 33% rather than 25%.

“notional banking surcharge profits”, in relation to the company, means the total of:

  • profits within section 85(5)(a) or 91(5)(a), to the extent that (assuming they were profits of the company chargeable to corporation tax) they would have been banking surcharge profits, and
  • any amounts of relevant taxable income of a company (“CC”) within section 85(4)(b) or (5)(b) or 91(4)(b) or (5)(b), to the extent that (assuming those amounts were profits of CC chargeable to corporation tax) they would have been banking surcharge profits of CC.