LDF and Swiss-UK Tax Agreement
untary disclosure for the one-off deduction, but with additional information regarding the total amount
of income and gains.”° In general, interest income, other income and capital are assessed based on the
amount before deductions.^' Gains from disposal of assets comprise the gain less acquisition and inci-
dental costs.^? Losses due to a disposal of assets can be offset against capital gains on future assets
with the same agent.*?
Choosing the one-off deduction to regularise past taxation does not prevent relevant persons from
choosing voluntary disclosure for future taxation, and vice versa.
3.4.4.3 Handling of Income
Interest income is interest credited to an account that relates to any debt-claims.^^ Additionally, any
interest income which falls under Council Directive 2003/48/EC (taxation on savings income), is seen
as interest income.*"
If a Swiss paying agent has no information about the interest proportion of an
income, the whole income is seen as interest.*^ Dividend income includes dividends credited on an
account." Other income is a substitute payment for dividends or interest (e.g. interest through struc-
tured instruments, swaps, securities lending, and repo business)."* AII gains due to disposal of assets
are capital gains."
Segregation describes the treatment of investments that have part interest income and part dividends or
capital gains (without the possibility of segregation) as interest income. The procedure is similar to the
Savings Directive and the handling of indefinable mixed funds under Liechtenstein tax law.
3.4.4.4 Process
Swiss paying agents have to collect the withholding tax when the income or gain is credited and must
send the tax, in sterling, to the Swiss tax authority within two months."? The Swiss tax authority must
^? CH-UK Tax Agreement, 2011, art. 22, para. 3.
^! CH-UK Tax Agreement, 2011, art. 24, para. 1-4.
^? CH-UK Tax Agreement, 2011, art. 24, para. 5.
^5 CH-UK Tax Agreement, 2011, art. 24, para. 6.
^^ CH-UK Tax Agreement, 2011, art. 25, para. 1, letter a.
^5 CH-UK Tax Agreement, 2011, art. 25, para. 1, letter c.
^5 CH-UK Tax Agreement, 2011, art. 25, para. 2.
^" CH-UK Tax Agreement, 2011, art. 26.
^5 CH-UK Tax Agreement, 2011, art. 27.
^? CH-UK Tax Agreement, 2011, art. 28.
#0 CH-UK Tax Agreement, 2011, art. 29 para. 1 & 2.
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