Volltext: The future importance of tax compliant clients

LDF and Swiss-UK Tax Agreement 
5 Conclusion 
5.1 Who Benefits from this Development? 
5.1.1 Initiators 
The initiators of this entire discussion about tax havens and the leading forces against tax evasion are 
certainly the European Commission, the United States of America, Germany and France. Surprisingly, 
until now, negotiation with these parties has seemed very difficult. The real profiteers are the United 
Kingdom and Austria. Although the UK still supports a large network of offshore jurisdictions and 
Austria provides strong banking secrecy, both were able to receive assets from Liechtenstein and 
Switzerland without giving something back. Of course, the agreements are technically reciprocal, but 
this is yet to be invoked and it is doubtful it ever will be. 
Germany returned the agreement with Switzerland and a likely subsequent agreement with Liechten- 
stein in December 2012. New negotiations between Germany and Switzerland have started, but until 
Switzerland once may agree in the future, Germany will lose at least one year of tax payback. Any 
automatic exchange of tax information which is implemented will last until 2015 or beyond. Therefore, 
the initiator of the whole process has not seemed to be a beneficiary until now. 
5.1.2 Liechtenstein & Switzerland 
At first glance, Liechtenstein and Switzerland appear worse off under these agreements compared to 
the situation ten or fifteen years earlier. However, looking deeper, it's clear that both have tried to 
make the best out of the situation. The negotiation of tax agreements is a proactive step and should be 
viewed positively. According to an old saying, "If you don't go forwards you go backwards". However, 
the question is whether the best was good enough. 
5.1.3 Other Jurisdictions 
In the near future, certain jurisdictions may profit from the pressure on Liechtenstein and Switzerland. 
Some clients have liquidated their structures and closed their accounts in both countries in order to 
transfer the assets to other jurisdictions. Which jurisdictions are profiting, can only be speculated. A 
short survey among financial intermediaries indicates that Delaware, Panama and Australia are in 
great demand. However, if the automatic exchange of tax information is implemented in a few years, 
all jurisdictions will be considered equal and factors such as performance, consistency and legal secu- 
rity will determine where the money flows. 


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