Entry into force on 22 December 2008 of a Protocol to the UK/Switzerland
Double Taxation Convention
A
Protocol to the Double Taxation Convention between the UK and Switzerland
was signed in London on 26 June 2007 and entered into force on 22 December
2008. The text has been published as the Schedule to The Double Taxation
Relief and International Tax Enforcement (Taxes on Income) (Switzerland)
Order 2007 (Statutory Instrument 2007 No 3465), copies of which can be
obtained from The Stationery Office. The text of the Order can be accessed
on the Office of Public Sector Information
website.
The draft Order was approved by Parliament on 27 November 2007 and
details of the debate can be found in the House of Commons Official Report,
Third Delegated Legislation Committee of 26 November 2007. Copies of the
Official Report are also available from the Stationery Office and may be
accessed on the
UK Parliament website.
The Protocol will make some amendments to the existing double taxation
convention, dated 8 December 1977. The main Swiss-UK Double Tax Treaty
amendments are the elimination of taxation at source on dividends where the
beneficial owner of the dividends has a substantial participation in the
payer or is a pension scheme. The Protocol also amends the exchange of
information article. It provides that, in future, information will be
exchanged in cases of tax fraud or the like, and in cases involving holding
companies.
The Protocol also contains measures relating to pensions. In future, lump
sum payments may be taxed only by the state in which they arise. Also,
pension contributions paid to a scheme recognised for tax purposes in one
country may, under certain conditions, be deductible in the other country.
The provisions will take effect from the dates set out in Article XIV of
the Protocol.
HM Revenue & Customs
December 200
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