LDF and Swiss-UK Tax Agreement
must be the owner of the bank account or a beneficiary. This also includes accounts held by founda-
tions or trusts.??
3.0 Current State of Research
To date, the Swiss Government has negotiated tax agreements with Germany, Austria and the United
Kingdom. The agreements with Austria and the United Kingdom have been in force since 1 January,
2013. The Swiss-UK tax agreement and the Swiss-DE tax agreement are almost identical, with only
slight variations.** First, there are differences between the tax systems, which require special rules for
non-UK domiciled individuals, who are taxed on a remittance base. Second, the domestic tax rates on
interest income, dividend income and capital gains are different in the UK, Germany and Austria, with
the effect that the tax rates for future taxation of these incomes and gains are notably higher in the
Swiss-UK tax agreement than in the Swiss-DE agreement. Third, there are some different procedural
arrangements in the agreements. Despite these differences, literature related to Germany and Austria
can be used to draw conclusions for the Swiss-UK tax agreement. The implementation, or projected
implementation, of the Swiss agreements in these three countries and the higher coverage of the
agreements has led to a higher amount of scientific research, especially in German journals.
Articles have been published in the Betriebs Berater Journal by Degen??; Ebner, Ebel & Hartrott” and
331 332
Gützenberger"' and in Zeitschrift für Stiftungswesen by Hosp & Langer. Further articles are availa-
ble in the European Taxation Journal, which published an analysis by Carelli**
, and by Koblenzer in
the Erbschaft- Steuer-Berater Journal**. Articles have been written in other journals by Patkos &
Gräfe***; Urtz**® and others. Because the agreements with the UK and Austria have only been in force
since January 2013, it is expected that further research, especially in the field of future taxation, will
be published shortly.
327 Urtz, 2012, p. 61.
#28 Carelli, 2012, p. 301-307.
329 Degen, 2012, p. 28-34.
#0 Ebner, Ebel & Hartrott, 2012, p. 287-294.
?! Gótzenberger, 2012, p. 2544-2545.
?? Hosp & Langer, 2011 (1), p. 121-127.
?? Carelli, 2012, p. 301-307.
31 Koblenzer, 2012 (1), p. 124-131 and Koblenzer, 2012 (2), p. 154-160.
?5 Patkds & Gräfe, 2012, p. 34-40.
36 Urtz, 2012, p. 60-63.
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