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HM Treasury has confirmed that a deal between the UK and Swiss governments has now been reached, regarding UK taxpayers' accounts held in Switzerland and the main points are:

1. For Swiss accounts that were open on 31 December 2010 and remain open at 31 May 2013, a 'one-off' charge of between 19 and 34% on the value of the funds held.
2. The one-off deduction will be deemed to settle Income Tax, Capital Gains Tax, Inheritance Tax and VAT due on those funds.
3. From 2013, the Swiss banks will operate a new withholding tax on UK taxpayers' funds - 48% on investment income and 27% on gains.
4. Whilst UK account holders will broadly retain their anonymity through these processes, HM Treasury says that the UK authorities will now have greater powers to access information about UK taxpayers holding accounts in Switzerland - i.e., more so than provided for under the terms of the UK-Swiss Double Taxation Agreement.
5. A UK account holder who wishes to avoid the blanket charges may instruct the Swiss bank to disclose their details to HMRC, in which case HMRC will seek unpaid taxes, penalties and interest due as normal.

In his recent article for TaxationWeb - Time to Look Again at The Liechtenstein Disclosure Facility? (LDF) - Andrew Watt mentioned that, running up to the deal, sources at HMRC had warned the rates would not compare favourably with those of the LDF - although in fact a 34% charge does seem a little better than the LDF's 'single composite rate' of 40%, plus 10% penalties, plus interest.

But there is no information as yet on what will happen to funds that have already left the account, or indeed which are closed before 31 May 2013. Presumably the one-off charge will be based on the funds present on 31 December 2010, to pre-empt any capital flight prior to May 2013.

Or maybe HMRC will prefer to wait to see what the balance is on 31 May 2013, and tax the funds that have moved from Liechtenstein to Switzerland?!

See also HM Treasury's press release at Agreement with Switzerland to Secure Billions in Unpaid Tax