The agreement will take effect in 2013 pending Parliamentary consideration and ratification in Switzerland, HMRC said in a statement, in which it described the deal as a “breakthrough” that “signals beginning of the end for offshore evasion”.
It is “expected to raise billions of pounds for the UK”, HMRC added.
Under the deal, any previously undisclosed assets held by UK taxpayers in Switzerland will be subject to a one-off deduction of between 19% and 34% to settle past tax liabilities.
From 2013, a new withholding tax of 48% on investment income and 27% on gains will be applied to these unnamed Swiss account holders, HMRC said.
However, “the new charges will not apply if the taxpayer authorises a full disclosure of their affairs to HMRC,” the Revenue added.
Additional features of the deal, according to HMRC, include:
– A “powerful” anti-abuse clause aimed at preventing prevent the promotion of tax avoidance by Swiss banks;
– A programme of audits, overseen by a new UK-Swiss joint commission, to ensure that Switzerland’s banks “are complying with their obligations”;
– Switzerland will collect data on the destination of funds withdrawn from the country following the announcement of this agreement, and will share that data with the UK;
– There will be no clearance of past liabilities for those involved in criminal attacks on the tax system or for anyone whose Swiss assets are the proceeds of non-tax crime