Following a recent HMRC briefing for professional advisers, Aileen Barry reviews the terms of the draft UK/Swiss Agreement, speculates as to how HMRC will interpret it and how the Swiss banks will implement it, and considers what the actual outcome will be
Ever since the announcement of the terms of the Memorandum of Understanding agreed between the respective governments of Liechtenstein and the UK concerning the Liechtenstein Disclosure Facility (LDF) in August 2009 there has been speculation as to what would happen in relation to UK taxpayers (or persons who ought to be taxpayers) holding undeclared Swiss bank accounts.
Many managers within Swiss banks actively drew their clients’ attention to the LDF as a means of resolving undeclared tax liabilities once and for...
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