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On 6 October 2011 the governments of Switzerland and the UK signed and published an agreement to co-operate on tax matters¹, which was finalised after scrutiny by Parliament² and ratification in Switzerland and came into force on 1 January 2013. This is not a disclosure facility, but it does give UK taxpayers an opportunity to bring their tax affairs up to date if they have not declared to HMRC income and gains arising on accounts in Switzerland.

The agreement provides for:

1. Ìý

   •ÌýÌýÌýÌý a one-off levy, in lieu of historic taxation liabilities, to be applied to financial assets in Switzerland beneficially owned by individuals resident in the UK, unless the individual authorises disclosure of those assets

2. Ìý

   •ÌýÌýÌýÌý a withholding tax to be applied to income and gains arising on those Swiss accounts from 1 January 2013, and

3. Ìý

   •ÌýÌýÌýÌý enhanced exchange of information between the tax authorities of the two countries

The agreement is supplemented by a Protocol, signed on 20 March 2012³ which:

1. Ìý

   (a)ÌýÌýÌýÌý introduces a