It may be remembered from earlier Tax Bulletins that the UK and Switzerland have signed a cooperation agreement whereby UK residents who have funds in Switzerland will suffer a substantial one off charge on their funds of up to 34% and a withholding tax on all future income and capital gains. This would naturally be of concern to those who are hiding money in Switzerland, but for those who make a full disclosure of all their income and gains to HMRC (to the extent that they need to – they may not if they are not UK domiciled) these swingeing deductions will not apply.
Concern had been raised whether such an agreement was in compliance with the EC Treaty – but some changes were proposed in the Budget to deal with these issues and on 17 April the European Commission issued a statement confirming that the agreement is in full compliance with EU law.
So the Swiss Cooperation Agreement is all systems go. It does not come into operation yet – not until January 2013 but it seems unlikely that anything will interfere with it now.
It may be remembered that the one off payment was calculated by the most unbelievable formula – it was so unbelievable it looked like a joke. However the joke is wearing a bit thin because they have decided to increase the maximum amount of the one off payment from 34% to 41% and have revised the formula. Trust me. You do not want to know.
I think that the Liechtenstein Disclosure Facility is still the best bet.