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HMRC internal manual

International Manual

Residence & non-UK domiciles: Effect of certificate

Once obtained, the certificate could have been presented to the Swiss paying agent for the purposes of qualifying for the non-domicile treatment in the agreement. However, acceptance by the Swiss paying agent should not necessarily be taken that HMRC will accept the non-domiciled status of any individual should the matter be subsequently taken up for enquiry.

Where that status claim is subsequently reversed by HMRC as a result of their enquiries or withdrawn by the individual, then any clearance received under the agreement will be reversed or withdrawn. Consequently, any tax payments made under the terms of the agreement will be treated as payments on account against remaining UK tax liabilities (Article 12(2) of the agreement).