The UK-Swiss tax treaty (announced in August 2011) has been signed and will come into force in 2013.
Initial details of the treaty were issued in August 2011, however further information on the precise terms of the agreement is now available.
Under the terms of the tax treatment, UK taxpayers may either:
1) Retain anonymity and suffer an initial one off deduction of between 19-34% and continue to pay a new withholding tax of 48% on interest, 40% on dividends and 27% on gains or;
2) Make a voluntary disclosure to HMRC regarding their Swiss assets and income.
If a disclosure is made, the accounts of UK taxpayer will not be subject to the one off deduction.
The treaty includes several anti-avoidance provisions including a clause aimed at preventing banks from promoting schemes to avoid the withholding tax by ensuring that such banks will become liable for the tax avoided.
If you would like to discuss the impact of the treaty further or would like help deciding which option to choose please feel free to contact us in our Leeds office.