LDF and Swiss-UK Tax Agreement 
Cg „If C49 € Cg 
Co, if Cg € Cg € 12 X Cg 
C, — max (3.5) 
1.2 x Cg 
2x 
lc, + 512 value increases + pe, outflows | Hf Cio 7 12 X Cigo 
Figure 1 Further explanation of the formula 
The following rule is established to prevent that the application of the formula for the capital 
element leads to a negative value: 
n 
C,—-— C, «0 
In case 8 , then this term is set equal to zero. 
The increased one-off payment T' 1s calculated as follows: 
Where tc 7 0.34 (meaning 34%) and: 
where 1m x C, « 2m, then tc' = 0.35 
where 2m < C, < 3m, then tc' = 0.36 
where 3m x C, « 4m, then tc' = 0.37 
where 4m < C, < 5m, then tc' = 0.38 
where 5m x C, « 6m, then tc'= 0.39 
where 6m < C, < 7m, then tc' = 0.40 
where 7m x C,, then tc' 7 0.41. 
The following applies: T" = tc"-C,. 
Source: Mutual Agreement, p.1., 2012. 
Table 10 Definition of variables 
  
T One-off payment I Yeari, 1 <i<10, where year 1 
starts on 1 January 2003 
  
T Increased one-off payment Ci Capital stock at the end of year i 
  
tr Rate (3496) Cs Capital stock at the end of year 8 
(31 December 2010) 
  
tc Tax charge Cio Capital stock at the end of year 10 
(31 December 2012) 
  
  
  
  
tc Increased tax charge Co, Cio Nominal capital at the end of year 9 
(31 December 2011), resp. year 10 
(V) 
C, Relevant capital R Rate of return (396) 
n Number of years in the bank rela- tfmin Minimum rate (21%) 
tionship before 31 December 2010, 
0<n<8 
  
  
72