LDF and Swiss-UK Tax Agreement
ments also apply to persons who are, or appear to be, UK resident but not UK domiciled for tax pur-
poses (sometimes referred to as being "UK res non dom").
According to our records, it appears that you, or the person(s) with a beneficial interest in the Relevant
Property referred to above ("Person(s) with a Beneficial Interest") are, or have been, resident in the
UK. Under the terms of the MoU, we are therefore required to formally notify you of the options that
exist so that you, or the Persons with an Interest, can demonstrate to us:
(1) that you, or the Person(s) with a Beneficial Interest, are not liable to UK taxation, or are com-
pliant with UK tax obligations, in relation to the Relevant Property (see paragraph [1] below); or
(2) that you, or the Person(s) with a Beneficial Interest, are not a "relevant person" as defined in
paragraph 1(0) of Schedule 1 to the MoU (see paragraph [2] below); or
(3) that you, or the Person(s) with a Beneficial Interest, have made a disclosure of relevant tax
liabilities to HMRC in relation to the Relevant Property by using the LDF (see paragraph [3] below);
Action required:
[1] If you, or the Person(s) with a Beneficial Interest, believe that you are a "relevant person” as
defined in the MoU but: (i) are not liable to UK taxation in relation to the Relevant Property or (ii) are
compliant with your UK tax obligations in relation to the Relevant Property, please return the enclosed
"Certification of Tax Compliance" to us duly completed and signed in original (photocopies will not
be accepted) or, alternatively, one of the documents mentioned in the attached “Checklist regarding
Tax Liability and Compliance”.
[2] If you, or the Person(s) with a Beneficial Interest, consider that you are not a “relevant person”
as defined in the MoU, please contact us for further guidance.
Due to the complexity of UK tax law and depending on your individual situation, it may be necessary
for you, or the Person(s) with a Beneficial Interest, to seek professional advice from a suitably quali-
fied lawyer or tax adviser in the UK before either relying on the "Certification of Tax Compliance"
referred to in paragraph [1] above or concluding that you are not a "relevant person” as mentioned in
paragraph [2] above.
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