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Wolf in sheep’s clothing?

01 November 2011 / Simon Airey
Issue: 4328 / Categories: Comment & Analysis , Switzerland , Admin
Or blessing in disguise? SIMON AIREY considers the UK-Swiss tax treaty


  • Clarification may be needed but the agreement is not ‘fatally flawed’.
  • Those under investigation will be unable to use the agreement.
  • Taxpayers with undeclared Swiss assets should consider the LDF.
  • When might an adviser have to make a suspicious activity report?
  • The consequences of a non-UK domicile opting out of the agreement.

Following the publication on 6 October 2011 of the terms of the agreement between the Swiss and UK governments (‘the agreement’) to enhance their co-operation in the area of taxation UK individuals holding undeclared bank accounts or other assets in Switzerland will no doubt have been anxiously reviewing the agreement in order to decide what to do next.

Should they regard the agreement as a blessing to be embraced...

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