LDF and Swiss-UK Tax Agreement 
atives from each state in order to examine the functioning of the agreement, assess developments and 
make recommendations.^? The agreement is in force until termination.** 
The implementation of a fee of 0.1% of all assets transferred for the Swiss tax authority seems low but 
is at least better than nothing. On transferred assets worth GBP 3 billion, the Swiss tax authority would 
receive GBP 3 million. This would cover part of the administration costs and pay additional employ- 
ees’ salaries. Even though the Liechtenstein tax authority sees less expenditure with the LDF, most of 
it is incurred by clients and FIs. It is regrettable that the Liechtenstein government was unable to nego- 
tiate a similar contribution towards expenses. 
Furthermore, it is noteworthy that the implementation of the agreement is fully audited by FINMA or 
auditing firms under control of FINMA, whereas for the LDF, a special, deeper audit is required for a 
group of FIs referred to in the “A List”. Switzerland did well in effectively standardising the audit 
procedure for all Swiss paying agents. 
3.4.6 Formulas 
Schedule 1 was replaced on 18 April 2012 with the Mutual Agreement, implementing Article XVIII of 
the Protocol signed on 20 March 2012, amending the agreement between the Swiss Confederation and 
the United Kingdom of Great Britain and Northern Ireland on cooperation in the area of taxation, 
signed in London on 6 October 2011 (Mutual Agreement). The new formula is as follows: 
Basic formula: 
  
2(c _n i 2 5 (Stl 
T= max!" * : (o Ex 0)+ WE x G+ Ex ( 2 )) (3.1) 
trmin X Cr 
Whereas: 
Co= Cr+ C, xr (3.2) 
Cia = C, C, X2xr (3.3) 
T 
tc = G (3.4) 
C. constraint : 
  
^35 CH-UK Tax Agreement, 2011, art. 41, para. 1 & 2. 
^^ CH-UK Tax Agreement, 2011, art. 45, para. 1. 
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