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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: Swiss tax certificates

During a compliance check you might identify that a UK resident individual holds a beneficial interest in assets or investments which are held offshore, see CH206570.

If an individual tells you about assets or investments held in Switzerland, not previously disclosed to HMRC, or you suspect evasion activity is linked to any assets located offshore, you must submit the case to the Evasion Management Team (EMT), as CH402170.

Where you establish that the individual holds either

  • a beneficial interest in Swiss assets at 31 December 2010 or
  • has income or gains arising in Switzerland from 1 January 2013 onwards

you may be presented by the individual with certificates of tax paid from a Swiss institution.

Where a one-off charge has been paid, the individual will have been provided with

  • a certificate confirming the value of income and gains on which the tax has been charged and
  • the amount of tax paid, see INTM820600.

Taxpayer need to retain these certificates to demonstrate to HMRC that no further liability arises on the relevant amounts of income or gains.

In most circumstances payment of the one-off charge or withholding tax will meet a customer’s liability to UK tax in relation to known assets or investments. Where the liability is met through the charge, or withholding tax, interest or penalties will not apply.

There may be further liabilities not covered by the payment, or assets which have not been included within the scope of charges made, see INTM820530.

For details on how to deal with the certificates, see CH206580.