Doesn\’t really quite get it:
Banks are supposed to withhold taxes first on the initial capital, then on interest, capital gains and capital income owned by their UK taxpayer clients. Now, a Swiss bank would rarely hold John Smith\’s account in the name of \”John Smith\” but in the name of, say, ABC Liechtenstein foundation or XYZ discretionary trust. Swiss sources indicate that some private banks don\’t hold a single account in an individual\’s name.
But said foundations and discretionary trusts aren\’t actually liable for tax. Therefore no tax is being avoided or evaded.
No tax is actually due.
So whining that the Swiss tax deal won\’t tax these entities which are not taxable is a little silly really, isn\’t it?