LDF and Swiss-UK Tax Agreement 
non-tax compliant clients.“ Credit Suisse and Julius Bár announced a demand for evidence of tax 
compliancy from German clients by the end of 2013. In addition, the Zürcher Kantonalbank pro- 
claimed that it only managed tax compliant assets in the medium term.* The withholding agreements 
with Austria and the United Kingdom came into effect in January 2013. 
1.5 Role of the UK 
1.5.1 Initial Situation 
The fall in tax revenues over recent years and the subsequent problems of United Kingdom (UK) na- 
tional budget has led to a stronger stance against tax evasion from the UK tax authority, Her Majesty's 
Revenue and Customs (HMRC)." The financial secretary to the Treasury, Stephen Timms, explained 
it as follows: 
“It 1s right for those who pay their fair share to resent the actions of a small minority, who use 
their resources to create a new set of rules for themselves. Who think they can pay tax on a 
"do it yourself" basis. That kind of behaviour certainly won't wash in the aftermath of the cri- 
Sis." 5 
Therefore, in 2009, the UK Government increased the penalties for individuals who fail to declare 
their income and gains from foreign jurisdictions up to 200% of the total tax due.® Furthermore, in 
April 2010, the Treasury declared that it would publish names and other details of tax evaders with 
serious tax offences. In line with the UK's new strategy against tax evaders, HMRC established two 
disclosure opportunities: the *New Disclosure Opportunity"? and the "Liechtenstein Disclosure Op- 
portunity" ?' These disclosure opportunities were followed by the UK-Swiss tax agreement in 2011 
and several other campaigns and initiatives.” 
  
8 Zeit Online, 2012. 
5 Süddeutsche, 2013. 
3$ Marquart, 2012. 
*' Anonymous, 2010, p. 56. 
8$ Grocott, 2009 (1), p. 18. 
¥ HMRC, 2012(6), p. 1 & 2. 
?! Closed in March 2010 
?' Monty, 2010, p. 15. 
?! HMRC, 2013 (1). 
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