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HMRC internal manual

Double Taxation Relief Manual

Switzerland: double taxation agreement, Article 28: Entry into force

(1) This Convention shall be ratified and the instruments of ratification shall be exchanged at Berne as soon as possible.

(2) The Convention shall enter into force immediately after the expiration of thirty days following the date on which the instruments of ratification are exchanged(a) and shall thereupon have effect:

(a) in the United Kingdom:

(i) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6 April 1978;  


(ii) in respect of corporation tax, for any financial year beginning on or after 1 April 1978;  


(iii) in respect of development land tax, for any realised development value accruing on or after 1 April 1978; and  


(iv) in respect of petroleum revenue tax, for any chargeable period beginning on or after 1 January 1978;  

(b) in Switzerland:

for any taxable year beginning on or after 1 January 1978.

(3) Notwithstanding the provisions of paragraph (2), the Convention shall have effect in respect of any dividend paid on or after 6 April 1975 to which paragraph (3) of Article 10 applies.

(4) Subject to the provisions of paragraph (5) the Convention between the United Kingdom of Great Britain and Northern Ireland and the Swiss Confederation for the avoidance of double taxation with respect to taxes on income signed at London on 30 September 1954, as amended by the Protocol signed at London on 14 June 1966 and by the Supplementary Protocol signed at London on 2 August 1974, (hereinafter referred to as `the 1954 Convention`), shall terminate upon the entry into force of this Convention and thereupon cease to have effect in respect of taxes to which this Convention, in accordance with the provisions of paragraph (2), applies.

(5) Where any provision of the 1954 Convention would have afforded any greater relief from tax any such provision as aforesaid shall continue to have effect:

(a) in the United Kingdom, for any year of assessment or financial year; and

(b) in Switzerland, for any taxable year beginning, in either case, before 1 January 1979.

(6) This Convention shall not affect any Agreement in force extending the 1954 Convention in accordance with Article XXI thereof.

(7) The Agreement of 17 October 1931 between the Government of the United Kingdom and the Swiss Federal Council for reciprocal exemption from taxation on profits or gains arising through an agency shall terminate upon the entry into force of this Convention.