This bar chart compares approximate US effective tax rates against UK marginal tax rates for different taxpayer bands. It shows a basic rate taxpayer with a US rate of about 12% against a UK rate of 20%, a higher rate taxpayer with a US rate of about 22% against a UK rate of 40%, an additional rate taxpayer with a US rate of about 24% against a UK rate of 45%, and a Scottish top rate taxpayer with a US rate of about 24% against a UK rate of 48%. The red sections highlight the extra UK tax gap that may arise after foreign tax credit relief. The graphic is intended to explain that the extra UK liability is driven by the difference between the UK tax rate and the effective US tax already suffered.