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HMRC internal manual

International Manual

The attribution of capital to foreign banking permanent establishments in the UK: The approach in determining an adjustment to funding costs - STEP 5: Determining the capital attribution tax adjustment: The range of capital attribution adjustment

UK-based banks, even banks carrying on broadly the same business activities, have a range of regulatory capital ratios. To some extent this reflects the individual requirements imposed on banks by the Financial Services Authority (FSA). This is not the whole story, however, since banks normally carry capital above that demanded by the FSA. This is one of the reasons why it is inappropriate to produce a safe harbour capital ratio for UK banks, which permanent establishments could use in preference to carrying out the calculation described in INTM267774 and INTM267775.

This also means that there is no ‘right answer’ when arriving at the equity and loan capital amounts required by CTA09/Part 2/Chapter 4. The answer is likely to be within a range of figures rather than set ratios such as ‘9% equity capital’ and ‘3% loan capital’.