LDF and Swiss-UK Tax Agreement
protection, estate and succession planning or capital preservation is still in keen demand by tax com-
pliant clients.“*
Bank Frick also seems to have very successfully implemented the LDF into its business strategy, since
it opened a branch in London to gain a physical presence. Bank Frick expects that around 10 to 20% of
its LDF clients will stay with the bank after the process is finished.?* Thus it seems clear that the LDF
has intensified the required cooperation with existing and new clients; this could establish a stronger
and more sustainable relationship for the future.
A further impact is the signing of several TIEAs and DTAs. The TIEAs were concluded due to the
pressure from the OECD to sign at least 12 TIEAs to get off their black list. This was a necessary
step. However, new TIEAs do not attract new clients. To attract foreign clients, the financial industry
needs new DTAs in order to provide offshore wealth management in compliance with tax law." Un-
fortunately, the promised network of double tax treaties is growing very slowly.
The conclusion of DTAs includes difficult negotiations and a great deal of time. Currently, only six
DTAs have been brought into force. This low number hinders development towards becoming a tax
compliant financial centre with an influx of new clients. However, the government announced in an
annual report that, in November, a DTA with Bahrain, and in December 2012, a DTA with Singapore
would be initialled. Further negotiations with Andorra, Belgium, Georgia, Guernsey, Ireland, Malta,
Slovakia, and Switzerland are ongoing. Negotiations with France, Italy, Spain and the US are due to
being soon.?*
Roth & Thiede concluded in their paper that “the LDF in the view of the authors is the only option to
exclude any future financial, civil, and criminal risks for the client and UK tax-payer and therefore
fully serves the client’s interests in the meaning of providing the client with banking client secrecy.”
5.6 The Future Trend of Tax Cooperation Agreements
Earlier articles about the Swiss agreements mention that the Swiss negotiator will soon begin negotia-
tions with other EU member states such as Italy and Greece.?? The Swiss Federal Council approved a
34 Frick, 2010, p. 475.
55 Bank Frick & Co. AG, 2011, p. 7.
5% OECD, 2010 (2), p. 2 & 3.
317 Goekmen, 2011, p. 26
395 Government of Liechtenstein, 2013, p. 59.
5? Roth & Thiede, 2013, p. 621.
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