Hard Swiss cheese

Levy paid by Swiss bank under the UK-Switzerland tax agreement

The taxpayer a Swedish national worked for Credit Suisse in Switzerland between 1998 and 2005 and then moved to London. She had three bank accounts with Credit Suisse into which she paid her earnings while an employee of the bank and her encashed Swiss pension. In 2012 Credit Suisse twice wrote to her to tell her about the UK-Switzerland tax agreement. It warned her that if she did not make a voluntary disclosure of her Credit Suisse accounts to HMRC the bank would take from her accounts an unspecified one-off payment calculated according to the formula in the agreement.

The taxpayer did not reply to those letters. As a result in 2013 Credit Suisse took £57 865 from her accounts and passed it to the Swiss Federal Tax Administration which transferred...