International treaty

Switzerland: tax treaties

Tax treaties and related documents between the UK and Switzerland.

• From: HM Revenue & Customs
• Published: 9 February 2011
• Last updated: 29 September 2021 — See all updates

Documents

1977 UK-Switzerland Double Taxation Convention as amended by the 2017 protocol – in force

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2017 UK-Switzerland protocol - in force

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2012 UK-Switzerland exchange of letters - in force

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2009 UK-Switzerland protocol - in force

PDF, 35.5 KB, 8 pages

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2008 Switzerland-UK memorandum of understanding on investment vehicles - in force

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2008 Switzerland-UK memorandum of understanding on pension schemes

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1977 UK-Switzerland Double Taxation Convention as amended by the 2009 protocol - in force

PDF, 575 KB, 33 pages

Switzerland-UK memorandum of understanding on arbitration under Article 24 of the Convention

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Details

2017 protocol

The protocol to the 1977 convention was signed on 30 November 2017. It entered into force on 19 July 2019.

The agreement takes effect in the UK from:

• 1 January 2020 for taxes withheld at source
• 6 April 2020 for Income Tax and Capital Gains Tax
• 1 April 2020 for Corporation Tax

The agreement takes effect in Switzerland from:

• 1 January 2020 for taxes withheld at source
• 1 January 2020 for other taxes

2012 exchange of letters

The exchange of letters entered into force on 19 December 2012.

2009 protocol

The double taxation agreement entered into force on 15 December 2010.

It is effective in Switzerland and the UK from 1 January 2011.

2008 Switzerland – UK memoranda of understanding on investment vehicles and pension schemes

Two memoranda of understanding were signed on 12 February 2008. They cover:

• a simplified procedure for refunding withholding taxes to collective investment vehicles
• the meaning of the term pension scheme

1977 Switzerland – UK Double Taxation Convention

The 1977 Switzerland – UK Double Taxation Convention entered into force on 7 October 1978.

It has been amended by protocols signed on 5 March 1981, 17 December 1993, 26 June 2007, 7 September 2009 and 30 November 2017.

It is effective in the UK from:

• 1 April 1978 for Corporation Tax
• 6 April 1978 for Capital Gains Tax

Switzerland-UK memorandum of understanding on arbitration under Article 24 of the Convention

The memorandum of understanding on the arbitration process under Article 24 of the Convention was signed on 16 June 2021.

Published 9 February 2011
Last updated 29 September 2021 + show all updates

1. 29 September 2021

   The document: Switzerland-UK memorandum of understanding on arbitration under Article 24 of the Convention was added to this guidance

2. 27 February 2020

   The 2008 Switzerland-UK memorandum of understanding on investment vehicles, 2008 Switzerland-UK memorandum of understanding on pension schemes and 1977 UK-Switzerland Double Taxation Convention as amended by the 2017 protocol – in force have been added.

3. 22 October 2019

   The 2017 UK-Switzerland protocol - in force has been updated.

4. 7 August 2019

   The 2017 Protocol 1977 Convention entered into force from 16 July 2016 and the 2017 Protocol to UK-Switzerland Double Convention have been updated on the page.

5. 18 January 2018

   The 2017 Protocol signed on 30 November 2017 has been added to the page.

6. 22 July 2016

   The 1977 Switzerland - UK Double Taxation Convention document has been added to this page.

7. 9 February 2011

   First published.