Introduction Background
5.The UK-Switzerland Agreement was signed on 6 October 2011. Schedule 36 to Finance Act 2012 was enacted to give the terms and principles of that Agreement statutory effect in the UK.
6.The Agreement is designed to provide an effective mechanism to enable HMRC to secure payment of both past and future UK tax liabilities in respect of assets located in Switzerland held by UK resident individuals. It does so by introducing an obligation on such individuals to make a one-off payment on 31 May 2013 to clear past unpaid tax liabilities and become subject to a withholding tax on income and gains arising from 1 January 2013.
7.The Agreement came into force on 1 January 2013 and this section will come into force from the same date.