Baker & McKenzie Holds Briefing on the UK-Liechtenstein and UK-Swiss Tax Compliance and Withholding Arrangements
14 June 2012
Zurich, Switzerland, 14 June 2012 - Within the framework of the regular business briefings organized by Baker & McKenzie Zurich, today Mr. Marnin Michaels, the co-head of Baker & McKenzie’s Global Wealth Management Group, welcomed the attendees to a briefing led by Elena Zafirova and Lyubomir Georgiev on the developments in relation to the UK-Swiss withholding tax agreement and the UK-Liechtenstein tax compliance arrangements.
Ms. Zafirova explained that once the withholding tax and information exchange agreement between Switzerland and the United Kingdom (the “Withholding Agreement”) is successfully ratified by each party in 2012 as expected, it will come into force on 1 January 2013. The Withholding Agreement is under review by the House of Commons today and expected to make its way through the House of Lords to Royal Asset before the summer break. The Swiss Parliament has its final vote on it on 15 June 2012 and it is not expected that there will be a public referendum on the Withholding Agreement.
Ms. Zafirova further lead the clarification of the provisions of the Withholding Agreement in relation to the relevant dates and the process whereby past undeclared assets of UK residents held with banks, securities dealers and other financial providers will be regularised and how future withholding will be applied. The different treatment of UK resident domiciliaries and UK resident non-domiciliaries was highlighted as well as the provisions in relation to UK inheritance law.
The briefing finished with an update by Mr. Georgiev on the latest developments in relation to the Liechtenstein Disclosure Facility (“LDF”) and the third joint declaration by Liechtenstein and HMRC. This includes the requirement for a meaningful connection to Liechtenstein for LDF purposes as well as the possibility of using a single charge rate for UK tax year 2010/2011 in addition to the composite rate option for years up to April 2009. The key provisions of the double tax agreement signed by Liechtenstein and the UK on 11 June 2012 were highlighted, including the general rule of exclusive taxation by the residence jurisdiction and mutual assistance in the collection of taxes.
For any questions about this press release, please contact:
Marnin Michaels (
+41 44 384 1208)
Lyubomir Georgiev (
+41 44 384 1490)
Elena Zafirova (
+41 44 384 1493)