BKLM740180 - Double Taxation Relief: France: split ownership

Regulation 10 of SI2012/458

With many banks being part of a multi-national group it is possible that the group may have entities subject to the bank levy which are held via different ownership chains and as such only some of the entities will be subject to two levies.

For example, a US bank has two sub-groups subject to the bank levy. One is held direct from the US while the other is held via a French intermediate holding company and is part of the French sub-group (see Diagram 1 (Word 29KB)).

In such a situation relief in respect of the French bank levy will only be due for the bank levy on the part of the group held via the French intermediary holding company. Regulation 10 restricts the credit available so that no double taxation relief will be allowed against the bank levy in respect of the sub-group held directly from the US.