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HMRC internal manual

Compliance Handbook

How to do a compliance check: establishing the facts: asking for information: UK / Swiss tax cooperation agreement: information subject to a request

Under the agreement the Swiss can provide details of

  • the number of accounts
  • the identity of the provider(s) of the accounts

that a UK resident has.

It will not provide

  • the balances
  • specific debits or credits
  • bank statements.

These details may be obtained using other information powers or through the double taxation treaty with Switzerland. However, you will need to demonstrate that you have exhausted all other possible alternatives first, see INTM156060.

Information requests must relate directly to individuals. It is expected that the majority of requests will be made in respect of individual Income Tax Self Assessment checks. However, requests for information are not restricted to any particular tax or duty under the agreement. For example, you may wish to make a request in connection with a director of a company that could lead to additional corporation tax. If you would like to make a request to Switzerland in respect of other tax and duties, please contact the OCU to discuss the circumstances.

Before you make a request, please ensure that you are not seeking information that may be obtained by using HMRC’s information powers under Schedule 36 Finance Act 2008, see CH23000. If you have evidence that an overseas bank account was established by using the UK branch of any bank, then you should consider making that branch subject to an information notice under these powers, see CH23810.