The transfer tax agreement between Switzerland and the United Kingdom entered into force on 1 January 2013. It enabled the regularisation of assets held by UK taxpayers in Switzerland and the taxation of income from these assets on the basis of the Federal Council`s financial integrity strategy. Under this agreement, UK taxpayers were given the option of either paying directly into their accounts and transmitting them anonymously to the UK authorities, or opting for self-declaration. However, with the introduction of the automatic exchange of information between Switzerland and the EU from 1 January 2017, which concerns the 28 Member States and Gibraltar, this model loses all its raison d`être. Chapter 9 shows how Switzerland has tried to propose an alternative model to the automatic exchange system in the form of the “Rubik agreements”. These agreements were concluded between 2012 and 2017 with Austria and the United Kingdom. They were in favour of a system of definitive withholding tax on the income of Swiss paying agencies, which corresponds roughly to the applicable rate of the Taxable Person`s State of residence. In January 2017, these agreements were repealed and replaced by a comprehensive bilateral agreement between Switzerland and the EU establishing the OECD standard for the automatic exchange of information. Switzerland has also concluded a withholding tax agreement with Austria, which will be denounced by the transition to the automatic exchange of information standard with the EU. The two countries signed an agreement to this effect on 11 November 2016. The transfer tax agreement between Switzerland and the United Kingdom was terminated on 1 January 2017 due to the entry into force of the agreement between Switzerland and the EU on the automatic exchange of information in tax matters.
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