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The Bank Levy (Double Taxation Arrangements) (Federal Republic of Germany) Regulations 2012
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14.—(1) This regulation applies to the presentation of a case concerning an entity’s being taxed (whether in the United Kingdom or the Federal Republic of Germany) otherwise than in accordance with the double taxation arrangements.
(2) The presentation of any such case under and in accordance with the double taxation arrangements—
(a)does not constitute a claim for relief under the Tax Acts or the enactments relating to capital gains tax, and
(b)is accordingly not subject to section 42 of the Taxes Management Act 1970(1) or any other enactment relating to the making of such claims.
(3) Any such claim must be presented before the end of the later of—
(a)the period of 3 years following the first notification of the action resulting in the entity being charged otherwise than in accordance with the double taxation arrangements, and
(b)the period of 6 years following the end of the chargeable period to which the case relates.
(1)
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