A number of changes have been announced to the terms of the agreement between the UK and Switzerland on cooperation on tax matters, which are expected to come into force on 1 January 2013. I believe the changes will prompt more individuals affected to make a separate disclosure to HMRC.
The changes to the UK/Swiss disclosure agreement announced on 20 March and 19 April are intended to smooth the passage of the draft legislation into UK law. They do so by addressing a challenge brought by the EU Commissioner for Taxation who said that the agreement contravened EU law as well as wider concerns that the payment required to cover historic tax liabilities was not set at a high...
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