Introduction Details of the Section
4.Subsection (1) is the enabling provision for the UK/Switzerland agreement signed on 6 October 2011 as amended by the protocol and mutual agreement. The protocol includes a Joint Declaration concerning the making of a tax finality payment in cases excluded from the agreement because they fall to be dealt with under the EUSA. The mutual agreement increases the levy for the past in line with the rates agreed between Switzerland and Germany.
5.Subsection (2) provides that the Schedule comes into force when the agreement enters into force. The agreement will enter into force on 1 January following the exchange of diplomatic notes confirming that the appropriate legal procedures in both countries have been completed. It is assumed for the purposes of these explanatory notes that the agreement will take effect on 1 January 2013. The section itself took effect on Royal Assent.
6.Subsection (3), in common with the approach for other international tax measures, disapplies the normal procedure for laying treaties before Parliament as part of the ratification process set out in section 20 of the Constitutional Reform and Governance Act 2010. Instead, the agreement received scrutiny as part of the Finance Bill process.