UK and International Tax news
Switzerland DTA Protocol
Tuesday 22nd February 2011
As reported in our International Tax News Item of 8 September 2009, a further Protocol to the Double Taxation Convention between the UK and Switzerland was signed in London on 7 September 2009. This has recently gone through the Parliamentary approval processes and came into force from the end of 2010.
Switzerland had announced in March 2009 that they would implement OECD standards on information sharing. This Protocol updates the exchange of information Article of the existing Convention to bring it into line with current OECD standards. In particular, and at Switzerland’s request, whilst it provides that bank secrecy is no longer a reason not to exchange the requested information, it is designed to provide reassurance that the UK will not engage in fishing expeditions to Swiss banks. The provisions are in line with what Switzerland has agreed with other countries, and do not prevent Switzerland agreeing at some future date to provide more information automatically or spontaneously.
The protocol also provides for arbitration if there is a dispute which cannot be resolved by the Competent Authorities of the two countries after three years. This is in line with modern UK treaties.
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