BKLM740240 - Double Taxation Relief: Germany: how relief is calculated

»Ê¹ÚÌåÓýapp protocol to the Double Taxation Convention (see BKLM740210 for a link to the convention) between the UK and Germany with regard to bank levies sets out how relief is to be calculated.

Step 1

Multiply the relevant liabilities of the Permanent Establishment (‘PE�) by the German bank levy rate applicable to the relevant liabilities.

Step 2

Multiply the relevant derivatives of the PE by the German bank levy rate applicable to the relevant derivatives.

Step 3

Calculate the proportion of any special contribution that is applicable to the PE.

Step 4

Add the results of Steps 1 to 3 together to arrive at the maximum amount of German bank levy for which relief can be given.

Note: When considering the relevant liabilities, derivatives and the proportion of any special contribution that are attributable to the PE, the 2008 OECD report entitled () should be used.

»Ê¹ÚÌåÓýapp German bank levy is subject to banding. »Ê¹ÚÌåÓýappre is no need to consider the bands when calculating the German bank levy rate under Steps 1 and 2. Instead the effective average rate should be used.