Merrill Lynch is unlikely to pay corporation tax in the UK for several decades after it charged €19.6 billion of losses to its London-based subsidiary, the Financial Times said citing a company filing.

The losses arose because almost all of Merrill's global activity in the market for repackaged debt, known as collateralised debt obligations (CDOs), had been channelled through Merrill Lynch International, its UK-based subsidiary, the paper said.

Last month, Merrill sold €20 billion of CDOs, to buyout firm Lone Star Funds, for €4.5 billion, or about 22 cents on the dollar.

After the latest sale, Merrill has a UK operating loss of about €19.6 billion that it can carry forward indefinitely for tax purposes, the paper said.

At the current corporation tax rate of 28 per cent, the bank will be able to offset losses against future profits, lowering its UK tax bill by as much as €5.4 billion, according to the paper.

Merrill could not be immediately reached for comment.