LDF and Swiss-UK Tax Agreement 
It has to be noted, that an outflow of assets after beginning of 2011 has no relevant influence on the 
final tax burden. A reduction of the tax burden is not possible except by closing the bank account and 
deposit before the end of 2012.“ 
3.5 Cases 
The cases illustrate the application of the Swiss-UK tax agreement. Further figures for these cases are 
available in Annex F. 
3.5.1 Case 1 
Case 1 is the case of Ms Brown introduced in 2.4.2. Because of her address in the UK, and since she 
had a bank account with a Swiss paying agent on the relevant dates, she has to pay the one-off deduc- 
tion or opt for voluntary disclosure. Table 11 shows the development of Ms Brown's account balance 
as well as the final tax burden as calculated using the formula. 
Table 11 Case 1 parameters and calculations 
  
  
  
  
  
Year Account balance | Interest and gains 
2004 GBP 350,000 
2010 GBP 446,647 GBP 25,282 
2011 GBP 451,114 GBP 4,466 
2012 GBP 478,181 GBP 27,067 
  
Relevant capital GBP 478,181 
Total tax burden | GBP 100,418 
  
  
Applicable tax rate | 21% 
  
  
  
  
  
Ms Brown has relevant capital of GBP 478,181. Her tax rate according to the formula is 2196. Thus 
she has to pay a total tax burden of GBP 100,418. Penalties and late payment interest are not owed 
under this agreement. As was shown in 2.4.2, under normal disclosure Ms Brown would face a tax 
burden of GBP 71,669 or 1596 of the total asset. Thus a voluntary disclosure under the Swiss-UK tax 
agreement would be cheaper for her. 
3.5.2  Case2 
Case 2 1s the case of Mr Thomson introduced in 2.4.3. Due to his address in the UK, and since she had 
a bank account at a Swiss paying agent on the relevant dates, he has to pay the one-off deduction or 
  
^? Gótzenberger, 2012, p. 172. 
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