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HMRC internal manual

Double Taxation Relief Manual

Switzerland: double taxation agreement, Article 2: Taxes covered

(1) The taxes which are the subject of this Convention are:

(a) in the United Kingdom of Great Britain and Northern Ireland: the income tax, the corporation tax, the capital gains tax, the development land tax and the petroleum revenue tax (hereinafter referred to as `United Kingdom tax`);

(b) in Switzerland: the federal, cantonal and communal taxes on income (total income, earned income, income from capital, industrial and commercial profits, capital gains and other items of income)

(hereinafter referred to as `Swiss tax`).

(2) The Convention shall also apply to any identical or substantially similar taxes which are imposed by a Contracting State or a political subdivision or a local authority thereof after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.

(3) The Convention shall not apply to the federal anticipatory tax withheld in Switzerland at source on prizes in a lottery.