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UK-Switzerland income tax treaty: memoranda of understanding

16 March 2008

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Treaty Development

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UK-Switzerland

On 12 February 2008, HMRC and the Swiss tax authorities signed two memoranda of understanding in relation to the UK-Switzerland income tax treaty of 8 December 1977. The first memorandum concerns the term "pension scheme" and sets out the various plans and schemes in both countries which come within the scope of that term. Additional schemes may be added, based on mutually agreed amendments to the memorandum. The second memorandum details a simplified procedure for refunding withholding taxes to collective investment vehicles. It replaces the memorandum of understanding of 18 January 2006. The Memorandum applies to pending and future claims...