Legislation will give effect to the agreement of 6 October 2011 between the UK and Switzerland on tax co-operation.

The Agreement will run from 1 January 2013 and involves a one off levy on Swiss accounts with a UK address if no disclosure is made to HMRC and further withholding at UK rates.

While anonymity will generally still be possible, HMRC will be able to ask the Swiss for full details in 500 cases each year.  Those potentially affected might find it makes more sense to transfer assets to Liechtenstein to take advantage of the terms of the Liechtenstein Disclosure Facility (LDF). Although the LDF requires full disclosure, there is a limit on how many years HMRC can assess, usually just a 10% penalty and a guarantee of no criminal prosecution for those admitted.

Who to contact?

Call Iain Macleod on 07920 146800 or 0115 983 5580, or contact him by email at imacleod@edftax.co.uk