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Paragraphs 66(1)(a) and (2) of Schedule 19

The legislation at paragraph 66(1)(a) refers to double taxation relief being afforded in respect of any � equivalent foreign levy�. Sub-paragraph 66(2) then explains that this means any tax imposed by the law of a foreign territory that corresponds to the bank levy.

To correspond to the UK bank levy and to be treated as an equivalent foreign levy the foreign levy must:

• broadly follow the proposals for the design of bank levies as set out by the IMF in their paper () published in June 2010, and
• be a levy based upon the balance sheet (on either assets or liabilities) and must be similar in intent to the UK bank levy

but

• it will not be an equivalent foreign levy if it is a tax on income, profits or gains.