The changes to the UK/Swiss disclosure agreement announced on 20 March and 19 April are intended to smooth the passage of the draft legislation into UK law. They do so by addressing a challenge brought by the EU Commissioner for Taxation who said that the agreement contravened EU law as well as wider concerns that the payment required to cover historic tax liabilities was not set at a high enough level for those that had not declared and paid tax on their Swiss assets.
The first key change is to exclude interest income from the scope of the ongoing 48% withholding tax where tax is already withheld at 35% under the EU Savings Agreement. Banks...
