UK agrees to terminate Swiss withholding tax arrangement

by Davide Anghileri

Switzerland and the UK will terminate their 2013 withholding tax agreement as of January 1, 2017, under a deal struck November 14.

The Swiss-UK withholding tax agreement provides that UK taxpayers may regularise the taxation of income generated by their assets held in Switzerland by either paying a withholding tax levied directly on their accounts which is anonymously transmitted to the UK authorities or opting for voluntary disclosure.

However, the UK no longer believes that withholding is necessary, given Switzerland’s decision to commence automatic exchange of information with the EU and Gibraltar as of January 1, 2017.

A similar agreement was signed by Switzerland and Austria on November 11.

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Davide Anghileri

Researcher and lecturer at University of Lausanne

Davide Anghileri is a PhD candidate at the University of Lausanne, where he is writing his thesis on the attribution of profits to PEs. He researches transfer pricing issues and lectures for the Master of Advanced Studies in International Taxation and Executive Program on Transfer Pricing.

Anghileri, a Contributing Editor at MNE Tax, previously worked as a policy advisor to the Swiss government on BEPS issues.

Davide can be reached at [email protected].

@DavideAnghileri

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Davide can be reached at [email protected].