In Karen Vrange v HMRC [2017] EWHC 1055 a taxpayer who ignored warnings about the Swiss bank levy was unable to claim back the levy paid under the UK/Switzerland cooperation agreement following disclosure of her offshore bank accounts.

  • The taxpayer was a Swedish national living in London.
  • Under the terms of the UK/Switzerland Agreement, UK taxpayers with Swiss bank accounts were given an opportunity to voluntarily disclosure their accounts or pay a levy.
  • She ignored warnings from her Credit Suisse bank about the potential levy and did nothing.
  • A levy of over £58,000 was taken from her accounts, she consequently disclosed them to HMRC and applied for a refund.

The High Court ruled that the levy was non-repayable: the UK/Swiss cooperation agreement did not provide provision for a refund and this was not contrary to the ECHR but proportionate.


The UK/Swiss agreement has now come to an end. Subsequently the UK have introduced new highly punitive tax penalties for those who chose not to disclosure their offshore assets or any income or gains. HMRC has opened a World Wide Disclosure opportunity for those who wish to get their affairs up to date.

Useful guides

What do they know? Client briefing on HMRC's information powers

HMRC current disclosure opportunties

Tax penalties: offshore - IT, CGT and IHT


Karen Vrange v HMRC [2017] EWHC 1055