The UK/Swiss co-operation agreement came into force on 1 January 2013. This is not a disclosure facility as such. In February 2015 HMRC created a standard disclosure pack for Swiss offshore disclosures.

Taxpayers with previously undisclosed Swiss assets have had the following options:

1. Make a one-off payment on 31 May 2013 to settle past unpaid tax liabilities based on account balances at 31 December 2010 or 31 December 2012.

  • This levy is paid at a rate of averaging 25% (but may be more or less) based on the number of years that assets have been held in an account since 31 December 2002. A withholding tax is paid from 31 December 2013.
  • This wipes the slate clean for the taxpayer in respect of past liabilities and preserves anonymity.
  • This option is unavailable if the account holder does not have sufficient funds to pay the levy or if they are currently under investigation.

2. Authorise their Swiss bank to provide details of their accounts to HMRC, and then pay withholding tax on income and gains from 1 January 2012.

  • If there are tax liabilities relating to earlier periods these should be dislosed to HMRC.
  • There are no special arrangements to discount penalties under the Swiss agreement.


3. Authorise their Swiss bank to provide details of their accounts to HMRC and then make a disclosure taking advantage of the Leichtenstein disclosure facility (LDF) (the LDF closed on 31 December 2015). 

4. Make full disclosure to HMRC. This can be done using the Worldwide disclosure facility (WDF) which remains available until 30 September 2018. Penalties will be applied on the normal scales for offshore income and gains.

5. Move their accounts to other jurisdictions before the levy (1.) become due.

HMRC guidance

Help sheet: The Swiss/UK Tax Cooperation Agreement and HM Revenue Customs (HMRC)

New@ February 2015: Swiss standard disclosure pack

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