The UK and Switzerland have entered in to an agreement which will come into force in 2013 whereby the whole of any funds held by UK taxpayers in Swiss acccounts will be subject to a charge of between 19% and 34% depending on how long the account has been open. This charge will cover all past tax liabilities to include income tax, CGT, IHT and VAT. It will apply to accounts which were in existence on 31 December 2010 and are still open on 31 May 2013.
From 2013 there will also be a withholding tax of 48% on income and 27% on capital gains together with information sharing provisions.
These charges will not apply if the taxpayer authorises full disclosure to HMRC because then HMRC will be able to pursue any unpaid tax liabilities in the normal way.
It is not clear what happens if funds are moved out of Switzerland before 31 May 2013, for example to Liechtenstein to take advantage of the Liechtenstein Disclosure Facility - although the liability under the LDF which includes interest and a 10% penalty could well be more than the charge under this new initiative.
The position of non- doms is unclear. There is some suggestion that UK non-doms will be able to escape these charges by providing appropriate assurance about their domicile status but no official confirmation in the UK or Switzerland has been published on this point.