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HMRC internal manual

Compliance Handbook

How to do a compliance check: starting a compliance check: offshore structures involving Swiss assets and investments: overview

Offshore arrangements by individuals could involve Swiss assets and investments.

If the offshore asset or investment is in Switzerland you will need to consider the effect of the terms of the UK Switzerland Agreement on tax cooperation (HMRC website).

There is more guidance at INTM800000.


The agreement provides UK resident individuals holding a beneficial interest in Swiss assets at 31 December 2010 with the choice of either

  • paying a one-off charge to address past UK tax liabilities or
  • authorising details of their assets to be disclosed to HMRC.

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Income and gains

The agreement also provides that UK resident individuals who have income and gains arising in Switzerland from 1 January 2013 onwards will either

  • be subject to withholding tax or
  • details of the income and gains will be disclosed to HMRC.

Where a one-off charge or withholding tax has been paid, the individual will have a certificate.