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Bank levy: double tax relief

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HMRC have invited comments on draft regulations allowing relief by way of credit for groups and entities subject to the bank levies of both the UK and France, where France is the home state of the entity or group.

The Bank Levy (Double Taxation Relief) Regulations 2011 will be made under powers contained in Sch 19 to the current Finance Bill, and have effect for periods of account ending on or after 1 January 2011.

'While the overall goal of [bank levies being introduced in a number of countries] is largely consistent, the application can vary considerably. In France, for example, the bank levy uses assets as the tax base, whereas in the UK, it uses liabilities,' said Chris Sanger, Global Head of Tax Policy at Ernst & Young, writing in Tax Journal (13 May).