TIOPA10/S43(1) will continue to provide symmetry in applying the provisions of CTA09/Part 2/Chapter 4 as the starting point in computing double taxation relief (DTR) for foreign tax on UK banks' overseas branches. It is possible that where the fiscal authorities in the host country apply a Basel I risk weighting regime while the UK bank as a whole applies a Basel II regime, that the profits attributed to the overseas branch exceed those that would be attributed using Basel II.

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