2011-02-24-KPMG_China-各国银行税建议的对比_6页_400kb

Bank Levies Comparison Summary

This report compares proposed bank levies in jurisdictions such as Austria, Cyprus, France, Germany, Hungary, Portugal, Sweden, UK, and US, focusing on legal status, scope, tax base and rates, and other issues post-G20 talks and EU agreements.

Overview

• Legal Status: Many countries have legislation in force or pending; e.g., Austria and Germany have it adopted, while Cyprus is not yet enacted. Start dates range from 2011 to uncertain periods, with durations like 10 years (Austria) or temporary (Hungary).
• Funds Raised: Contributions support stability funds, like Treasury funds in Austria and KPMG funds in other jurisdictions, aimed at crisis relief and repaying programs.

Scope

• Definition of Bank: Defines vary; e.g., Austria has a narrow definition based on credit institutions, while the US includes broker dealers.
• Coverage: Most jurisdictions target banks and related entities; e.g., Austria excludes certain foreign branches, and Sweden focuses on financial institutions. Exclusions include interbank loans and government-backed deposits.

Tax Base and Rates

• Tax Base: Primarily balance sheets or liabilities; e.g., France uses minimal funds requirement, while US includes derivatives. Thresholds start from €500 million for Cyprus, with rates ranging from 0.025% to 1%.
• Rates: Austria has triggers and progressive rates, while Portugal has a fixed setup. Exclusions include Tier 1 capital in some cases.

Other Issues

• Double Taxation: Risk exists with potential tax credits; e.g., France allows credits for foreign levies in some cases.
• Deductibility for Corporate Tax: Uncertain or varies; e.g., some countries like Germany allow deductions, while others like Portugal impose caps. Crude taxation risk mitigation through agreements.