The High Court dismissed a claim that HMRC should refund deductions from a Swedish National’s bank accounts in Switzerland under the UK-Switzerland tax agreement, which were in excess of the individual’s actual tax liabilities for the relevant period.
The claimant, a Swedish national, worked in Switzerland between 1998 and 2005, when she moved to London. She had bank accounts in Switzerland. The bank wrote to the claimant in July 2012, and again in September 2012, alerting her to the agreement ‘on cooperation in the area of taxation’ dated 6 October 2011, between the UK and Switzerland.
The bank’s letters warned the claimant that if she did not give voluntary disclosure of her bank accounts to HM Revenue and Customs (HMRC), the bank would take from her accounts an unspecified one-off payment, calculated by reference to a formula in the agreement. This payment would absolve her from all past UK
