See the main part of the cooperation agreement between the UNITED Kingdom and Switzerland: tax cooperation agreement for the comprehensive whistleblowing agreement. The initial agreement is also available. On 6 October 2011, the United Kingdom and Switzerland signed and published the text of their tax agreement for UK residents with accounts in Switzerland (the “agreement”). The publication of the agreement is good news, as it provides a welcome clarification on a number of issues that (as noted in our previous Stop Press of 13 September 2011) were not clear from the previously published information. On the other hand, it also confirmed that the agreement had some important restrictions. Upon entry into force of the agreement, a qualified non-Dome is automatically subject to withholding tax on UK revenues and profits, as well as income and profits from foreign sources transferred to the UK, unless it authorizes the bank to disclose to HMRC the details of these revenues and profits. It will not be able to opt out of this part of the agreement. On 14 November 2016, HM Revenue and Customs Permanent Secretary and Executive Chairman Edward Troup and the Swiss Ambassador to the United Kingdom, Dominik Furgler, signed an agreement ending the tax cooperation agreement between Great Britain and Switzerland. This protocol highlighted the relationship between the agreement and the EU austerity agreement (EEA) with Switzerland – if a person concerned has been subject to withholding tax under the EEA, an additional 13% “final tax payment” must be paid to obtain tax assistance in accordance with the terms of the agreement. This had the same effect as the 48% withholding tax, levied in accordance with the original provisions of the agreement. On 20 March 2012, the United Kingdom and Switzerland signed a protocol to the tax treaty. The OECD`s Multilateral Convention on the Implementation of Measures to Prevent Erosion and Profit Transfer (“Multilateral Instrument” or “MLI”) of the OECD came into force in the United Kingdom on 1 October 2018 and will have a fundamental influence on how taxpayers have access to the double taxation (DT) conventions to which they apply.
It began from 1 January 2019 (z.B with regard to WHT) for the UK DT, with the territories also ratified before 1 October 2018, in which these are tax treaties. The specific dates on which the MLI takes effect for other purposes or for other TDAs depend on when other contracting parties submit their ratification instruments to the OECD and the options and reservations they have submitted.