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United KingdomGOV.UK

Banking surcharge doubles to 6% for 15 months from January 2027

Straddling periods split around 1 January 2027 and 1 April 2028 with time apportionment; instalments due by 28 October 2026 ignore the rise and catch up in the next payment.

By Taxxa AI OyPublished 6 November 2026

Tax

Industry: Financial service activities, except insurance and pension funding

Banking companies face a temporary doubling of the corporation-tax surchargeGOV to 6% from 1 January 2027GOV, reverting to 3% from 1 April 2028GOV. The change is set out in Clause 7 of the Finance Bill 2026-27GOV, which is subject to Royal AssentGOV, with provisional statutory effect from the Budget Resolution of 28 October 2026GOV under the Provisional Collection of Taxes Act 1968.

An accounting period straddling either date is split into two notional periods for surcharge purposesGOV: a period straddling 1 January 2027 becomes one period ending on 31 December 2026 and one commencing on 1 January 2027GOV, and a period straddling 1 April 2028 becomes one ending on 31 March 2028 and one commencing on 1 April 2028GOV. Surcharge profits of the straddling period are apportioned between the two notional periods on a time basis or, where that would be unjust or unreasonable, on a just and reasonable basisGOV. The surcharge allowance for each notional period is calculated proportionally on a time basis under subsections 269DE(5) and 269DJ(4) of CTA 2010.

Quarterly instalment payments need special handling for January 2027 straddling periods. An instalment due and payable on or before 28 October 2026 is determined as if the rate rise had not been madeGOV, so early instalments for such periods do not reflect the 6% rateGOV. The shortfall is then added to the company's first instalment due and payable after 28 October 2026GOV.

The manual works this through for a banking company with a 12-month period ending on 31 March 2027 and an estimated GBP 200 million of surcharge profits exceeding the allowance. Before the Budget it expected a GBP 6 million liability at 3% and paid GBP 1.5 million each on 14 June and 14 September 2026. Apportioned on a time basis, the revised liability is GBP 7,479,452GOV: GBP 150,684,931 for the 275 days to 31 December 2026 at 3%, giving GBP 4,520,548, and GBP 49,315,068 for the 90 days from 1 January 2027 at 6%, giving GBP 2,958,904. Each instalment should now be GBP 1,869,863GOV, so GBP 369,863 was left out of each of the first two paymentsGOV. The GBP 739,726 catch-up is added to the third instalment on 14 December 2026GOV, making GBP 2,609,589GOV, with a final GBP 1,869,863 on 14 March 2027GOV.

Legal basis: Finance Bill 2026-27, Clause 7; Provisional Collection of Taxes Act 1968; CTA 2010 subsections 269DE(5) and 269DJ(4).

Split straddling periods around 1 January 2027 and 1 April 2028, apportion profits, and add any pre-29 October 2026 instalment shortfall to the next quarterly payment.

Sources