LDF and Swiss-UK Tax Agreement
negotiating mandate with Greece in November 2012.°' An agreement with Italy has moved beyond
reach.” An agreement with France was refused initially but this could change in the future if need for
revenues continues.” Further negotiations with additional states are not officially confirmed. Nor
have any further negotiations with other states been officially announced by the Liechtenstein gov-
ernment.
It is questionable whether the Liechtenstein government will negotiate further agreements based on the
LDF, due to the recent switching to the Swiss draft for its agreement with Austria. This shows incon-
sistency in the implementation of the Liechtenstein Declaration and lack of confidence in the agree-
ment philosophy. Furthermore, two different solutions to reach more or less the same goal increase
compliance costs for banks and other financial intermediaries in Liechtenstein. Different IT solutions
are needed for each agreement, and employees will require external training and a period of vocational
adjustment. Furthermore, to a certain degree, the whole staff will require some information in order to
understand the philosophy and gain a narrow understanding of the process. This cost of expenditure
cannot be fully charged to the clients. From a financial point of view, the agreements are not profitable
for Liechtenstein and Swiss financial intermediaries.
In addition, the lack of further agreements from Switzerland indicates that the negotiations are inter-
minable and unsuccessful, especially after Luxembourg and Austria agreed to reduce their banking
secrecy and allow an automatic exchange of information about interest earnings. According to Jean-
Claude Juncker, head of government in Luxembourg, a precondition for this easing is that third states
like Switzerland also agree to an automatic exchange.?" In its press release from 12" of June, 2013, the
European Commission proposed a memo in order to extend the automatic exchange of information.^'?
This directive is schedule to be brought into force at the beginning of 2015 and should also include
516
Switzerland, the Cayman Islands and the British Virgin Islands.
How long Switzerland and Liechtenstein are able to defend against this development in the European
Union is strongly questionable. Since employees of banks and other financial intermediaries would be
?? Hosp & Langer, 2011 (1), p. 126.
SU Klenger, 2013.
512 Tzermias, 2013.
51 Gilleard, 2011, p. n/a.
?^ Handelsblatt, 2013.
515 European Commission, 2013.
“16 Mülherr, 2013.
91