Fewer untaxed UK assets in Switzerland than predicted

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Fewer untaxed UK assets in Switzerland than predicted

swiss-flag.jpg

The Swiss Bankers Association (SBA) has stated that Switzerland’s tax agreement with the UK, which entered into force on January 1 2013, will result in far less revenue for the UK exchequer than previously assumed.

The tax agreement means that accounts held by UK taxpayers in Switzerland will be hit with a flat-rate anonymous withholding tax charge, unless taxpayers disclosed the assets by the end of May – a deadline which has now passed.

“The agreements provide for an anonymous withholding tax for banking relationships,” said Dieter Weber, founding partner of Tax Partner – Taxand Switzerland. “Swiss banks deduct a flat rate tax on existing assets from UK clients (past) and on investment income and capital gains (future) and forward the corresponding tax amount anonymously to the Swiss Federal Tax Administration to be transferred to the tax authorities in the UK.”

The anonymous withholding tax is a final withholding tax, so once it is paid the tax liability is considered settled.

But despite the mechanism being up and running, the SBA says that first indications from selected banks in Switzerland indicate there are fewer untaxed assets in the country than previously assumed.

This is mainly because many clients have resident non-domiciled status.

“These clients are not liable to taxation in the UK, and thus do not fall under the agreement,” the SBA statement said. “Furthermore, numerous UK clients have opted for voluntary disclosure, which comes as no surprise given the latest developments in Switzerland with regard to the announced adoption of a global standard for the automatic exchange of information.”

The SBA said that as a result of these initial findings, less tax than expected is being transferred to the UK by means of the one-off payment.

“The possibility can therefore not be ruled out that either none or only a small part of the banks’ guarantee payment of CHF 500 million ($516 million) will be recovered,” said the SBA statement.

more across site & shared bottom lb ros

More from across our site

It continues a prolific spree of investment for the firm, after it launched in Indonesia, Thailand, Saudi Arabia and Japan in 2025
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Partners at both firms have voted in favour of the tie-up, which marks ‘the largest law firm merger in history’
The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR
New hires from rivals are reportedly being axed from the firm, following a steep decline in profits
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
Gift this article