(4) Subject to paragraph 5 of the agreement between the United Kingdom of Great Britain and Northern Ireland and the Swiss Confederation on the Prevention of Double Taxation on Income Tax, signed in London on 30 September 1954, in which, as it was lowered, on 14 September 1954. The protocol signed in London on 2 August 1966 and the additional protocol signed in London on 2 August 1974 (the so-called “1954 agreement”) expire upon the entry into force of this Convention and, therefore, the effect on the de-tussia to which this Convention applies under paragraph 2. The convention was provided for in the order of double taxation (Switzerland) of 1978 (S.I. 1978/1408) and had previously been adopted by the 1982 decrees in the schedules to the Double Relief Taxation (Switzerland) (S.I. 1982/714), 1994 (S.I. 1994/3215) and 2007 (S.I. 2007/3465), as well as the international enforcement decision on double taxation and tax enforcement (Switzerland) 2010 (S.I. 2010/2689). The agreement was also supplemented by the agreement attached to the 2012 Regulation (S.I. 2012/3079) on double taxation relief and the enforcement of international tax (Switzerland). The change protocol will come into effect through the decision.
On 13 March 2009, the Federal Council announced that Switzerland intends to adopt OECD standards for mutual tax assistance, in accordance with Article 26 of the OECD Model Tax Convention. The decision allows the exchange of information with other countries in individual cases where a concrete and reasoned request has been made. The Federal Council has decided to withdraw the reserve for the OECD`s model tax treaty and to begin negotiations on the revision of double taxation conventions. However, Swiss banking secrecy remains intact. HMRC has reached an agreement with the Swiss tax authorities. The agreement allows for close cooperation between the UK and Switzerland, and there is an important exchange of information between the two countries. The agreement provides for a historic tax on Swiss funds held by residents in the UK, up to 34% of the balance in an account as of 31 December 2010 or 31 December 2012. UK residents with Swiss accounts may also be subject to a WHT of up to 48% on their accounts. With regard to inheritance tax, Swiss payers are required to withhold 40% tax or to file a declaration if a person dies, as well as other measures. (a) with respect to the amendments to Article 24 (mutual agreement procedure) of the convention by Article IX of the Amendment Protocol, from the date of the amendment protocol`s entry into force, without taking into account the tax period to which the case relates, where income is still taxable in both countries, double taxation must be granted by the taxpayer`s country of residence. There are also provisions that protect nationals and businesses in one country from discriminatory taxation in the other country, as well as for the exchange of information and consultations between the tax authorities of the two countries. CH-UK Double Taxation: 0.672.936.711 – 0.672.936.73 (en, Fr, it) (2) (2) When a State Party has earned profits collected by a company of the other State Party and the items thus included include income, deductions, revenues or expenses that would have been charged to the company of the first state if the conditions between the two companies had been between them, the competent authorities of the States Parties may consult jointly to reach an agreement on the adjustment of profits or losses in the two States parties.