LDF and Swiss-UK Tax Agreement 
tionary power was with the board. However, from a recent case, Swiss banks are satisfied with a letter 
sent by the board of a foundation confirming the discretion of the foundation and the irrelevance of the 
banked assets to the Swiss-UK tax agreement. 
The Swiss-UK tax agreement and the LDF are not mutually exclusive. On the contrary, UK- 
individuals with assets in Switzerland and assets in Liechtenstein or other jurisdictions are able the 
regularise the Swiss assets via the Swiss-UK tax agreement and regularise all other assets with the 
LDF.** 
3.7 Conclusion of the Agreement 
3.7.1.1 Clients 
For clients with bankable assets in Switzerland this agreement allows them to solve their tax issues 
and leave the asset anonymously in Switzerland. However, if there are further assets in other jurisdic- 
tions or assets which are not booked on a bank account, the agreement is only of limited use. Some of 
the tax issues remain unresolved. The tax rate is acceptable but also includes an anonymity premium 
as the comparison cases show. The option to choose voluntary disclosure or the LDF is open for every 
client and should be taken into consideration. 
3.7.1.2 Financial Intermediary 
For Swiss banks, the agreement is a chance to mitigate the risk of UK untaxed assets in a simple way. 
Implementing the required IT systems should pose few problems. Handling any future withholding tax 
should also be possible with the requisite effort. The agreement secures the bank and its employees 
from prosecution. However, problems with untaxed foreign assets could run out of control, as demon- 
strated by the recent problems Swiss bank Wegelin & Co bank faced with the “Lex USA". Even if 
some clients leave, Swiss FIs should view the Swiss financial market as positive due to the decreased 
risk. 
3.7.1.3 Switzerland and United Kingdom 
As Perdelwitz states, the agreement is advantageous for Switzerland. The Swiss financial sector will 
improve its image by henceforth accepting only taxed funds from individuals from the UK and Austria. 
This will reduce any claim these countries might have for an automatic exchange of tax information. 
Perdelwitz complains that this as a not a win-win agreement for the Swiss contracting partners. Each 
contracting partner receives huge support for the national budget due to the regularisation of the un- 
taxed funds and a further amount of money every year annually. In return, the states must recognise 
  
^5 Roth & Thiede, 2013, p. 621. 
77
        

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