Private Client Focus - Switzerland

04 April 2022

Welcome to ‘Private Client Focus’, our newsletter keeping you up-to-date with the latest news and updates that may affect you as a private individual. In this edition, we focus on Switzerland.

We advise private individuals and their advisers based in Switzerland and across the world, and have extensive experience in the specialist tax, residence and advisory issues facing this jurisdiction.

For further information and detail, take a look at our dedicated private client hub – the World of Private Clients. Our international team provide an overview of Switzerland and it's key tax information as a private client hotspot.

Interaction of UK CGT and fluctuating exchange rates

International property or investment transactions create a range of tax complexities for UK residents individuals should be aware that the UK tax payable on such disposals may not reflect the true economic position. A small gain on overseas property can become a big tax problem because of currency fluctuations.

READ OUR SUMMARY

Latest update on HMRC nudge letters

We cover the latest round of nudge letters sent by HMRC which include looking into discrepancies of crypto-assets.

Transparency update from the OECD

We analyse the OECD's latest Transparency report and discuss what it means for Swiss Trustees. We also explain another level of reporting required by Trustees starting in April 2022.

Update on the UK Trust registration service

From 6 October 2020, as part of the UK’s implementation of the Fifth Money Laundering Directive (“5MLD”), the registration requirement was extended to include the following trusts (again with limited exceptions).

European Property Tax Guide 2021

For families, the complexity of owning a foreign home or property investment is increasing, so it is vital that prospective owners understand the tax and legal context for any country in which they intend to invest. This guide provides a summary of the legal and tax rules for foreigners buying real estate in Europe, including in France, Germany, Netherlands and the UK.

Domicile issues and HMRC enquiries

A number of recent Tax Tribunal cases concerning domicile enquiries reflect what we are seeing in practice – that HMRC is increasingly questioning domicile status.

Tax Day - The personal tax implications

We look at the UK's recent Tax Day, following the Budget, and the updates and implications that arose from a personal perspective.

Domicile Enquiries – Partial Closure Notice requests

Those subject to ongoing HMRC domicile enquiries were no doubt awaiting with interest the eagerly anticipated decision of the Upper Tier Tribunal in the case of HMRC v Epaminondas Embiricos [2020].
We explain the outcome of the case.

HMRC issues a new round of nudge letters

HMRC has issued a new round of nudge letters to clients and their advisors, as they continue to actively seek compliance with offshore matters and to prompt disclosures.

EU Settled Status: Applications and Impact on Domicile Status

Alongside leading immigration firm Fragomen, our team update you on the situation with EU settled status before the UK leaves the EU.

HMRC nudge letters – an update

HMRC typically issues ‘nudge’ letters to taxpayers in large batches and usually after it processes data received from overseas tax authorities under the Common Reporting Standard.

HMRC data collection: requests for information and Trust registration

It is apparent that there have been a number of HMRC enquiries targeted at settlors of non-UK trusts that benefit from ‘protected’ status.

Inheritance Tax – taking a long term view

In this update we highlight some of the Inheritance Tax issues that should be taken into account during these conversations.

Update on the taxation of UK land

In this update we cover updates to SDLT surcharges and disposals of UK land.

Recent Swiss regulatory changes

We give a round up of recent Swiss regulatory changes that affect Trustees, with a focus on supervisory legislation that came into force on 1 January 2020.

Current travel disruption – Tax issues facing Swiss trustees

From our conversations with Swiss intermediaries, it is clear that a number of tax issues have arisen from the restrictions on travel that are currently being imposed due to COVID-19. In this update, we consider how individuals and companies are being affected and how HMRC are responding to these challenges.

KEY CONTACTS

Paul Ayres

National Head of Private Clients

BDO London - Baker Street

Dawn Register

Head of Tax Dispute Resolution

CTA, TEP

BDO London - Baker Street

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