LDF and Swiss-UK Tax Agreement 
The exclusion of gold, real estate and safety deposit boxes could present a loophole but also a problem 
for some persons.” 
If someone wants to regularise his Swiss assets but also has gold bullion in a safe- 
ty deposit, he is not able to regularise this via the agreement. After the one-off deduction, the tax lia- 
bilities of the bankable assets are compensated, but the tax liabilities for the gold bullion are not. It 
would have been possible to liquidate the gold before 31 December 2012, but this would still have 
been subject to the “20% cap” problem, as explained in chapter 3.4.6. 
3.4.3.2 One-Off Payment 
If a relevant person opts for a one-off payment, the Swiss paying agent must collect the assets.” In 
general, the tax rate is 34%.%” The account and deposit must have been made since December 31 2002 
for the tax rate to apply? The tax rate is based on the following factors? 
e The date the bank account was opened. At most back to 31/12/2002 
e The asset value on this opening date 
e The asset value on 31/12/2010 
e The change in asset value in 2011 and 2012 
e The final value of the asset on 31/12/2012 
After the payment, the Swiss paying agent has to issue a certificate for the relevant person and the 
person has 30 days to enter any opposition." After these 30 days, the Swiss paying agent forwards the 
payments to the Swiss tax authority on a monthly basis. After a further month, the Swiss tax authority 
forwards the payments to HMRC. HMRC should therefore receive the final payment on 1 February, 
2014. Payments which are delayed due to legal proceedings or similar must be transferred immediate- 
ly after the problem is solved.?? All transactions are made in sterling.?? After the certificate is issued, 
all tax liabilities, income tax, capital gains tax, inheritance tax, and VAT for the relevant assets are 
regularised for the past.*®' 
The one-off deduction is not available for persons under investigation by 
HMRC or if the relevant person is already part of a disclosure or if the assets are from criminal pro- 
ceeds or fraud.?*? 
  
313 Urtz, 2012 (1), 61. 
7% CH-UK Tax Agreement, 2011, art. 9, para. 1. 
?5 CH-UK Tax Agreement, 2011, art. 9, para. 2. 
76 Urtz, 2012 (1), p. 62 & 63. 
77 Koblenzer, 2012 (1), p. 128. 
?5 CH-UK Tax Agreement, 2011, art. 9, para. 4. 
?? CH-UK Tax Agreement, 2011, art. 9, para. 5. 
380 CH-UK Tax Agreement, 2011, art. 9, para. 6. 
331 CH-UK Tax Agreement, 2011, art. 9, para. 7, 8 & 10. 
38 CH-UK Tax Agreement, 2011, art. 9, para. 13. 
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