On 18 January 2006, a protocol modifying the tax treaty between the United Kingdom and Switzerland of 8 December 1977 was initialled. The main modifications include: -   reduction of withholding tax on dividend to 0% for (i) corporate shareholder owning a substantial participation in the dividend distribution company, or (ii) pension schemes; and -   extension of exchange of information under Art. 25 Furthermore, the protocol contains new measures regarding the taxation of pension income, and the tax deductibility of social and pension scheme contributions. In future, lump sum payments may be taxed only by the source state, and...