Update on the UK/Swiss Tax Agreement

Aileen Barry

Speed read

The UK/Swiss Special Tax Agreement published on 6 October is expected to take effect from January 2013. The Agreement aims to establish effective taxation of relevant persons through co-operation between the authorities, although without complete transparency in relation to the identity of taxpayers it may be difficult to monitor success.

Under the terms of the Agreement, a UK domiciled individual must authorise the Swiss paying agent either to disclose their details to the Swiss tax authority to pass on to HMRC, or to deduct the historic payment. A non-UK domiciled individual effectively has three options: he can authorise disclosure, instruct regarding the terms of the historic deduction, or ‘opt out’.

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