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1Article 1 · Personal scope2Article 2 · Taxes covered3Article 3 · General definitions4Article 4 · Residence5Article 5 · Permanent establishment6Article 6 · Income from immovable property7Article 7 · Business profits8Article 8 · Shipping, inland waterways transport and air transport9Article 9 · Associated enterprises10Article 10 · Dividends11Article 11 · Interest12Article 12 · Royalties13Article 13 · Capital gains14Article 14 · Independent personal services15Article 15 · Dependent personal services16Article 16 · Directors’ fees17Article 17 · Artistes and athletes18Article 18 · Pensions19Article 19 · Government service20Article 20 · Students21Article 21 · Other income22Article 22 · Elimination of double taxation23Article 23 · Non-discrimination24Article 24 · Mutual agreement procedure25Article 25 · Exchange of information26Article 26 · Diplomatic agents and consular officers27Article 27 · Miscellaneous rules27aArticle 27A · Entitlement to benefits28Article 28 · Entry into force29Article 29 · TerminationPreamble · Title, publisher explanation and complete preambleSignature · Signature and authentic-language clauseAdditional Protocol · Integral Additional Protocol dated 7 September 2009

30 articles · English

Source & edition
Country pairs / Switzerland / United Kingdom

Switzerland / United Kingdom · Switzerland–United Kingdom 1977 Convention: official amended publication

Article 28 · Entry into force

English · amended source publication

Unreviewed · applicability unverifiedProtocol entry-date conflict: 16 / 19 July 2019
Original & source
§
(1) This Convention shall be ratified and the instruments of ratification shall be exchanged at Berne as soon as possible.
§
(2) The Convention shall enter into force immediately after the expiration of thirty days following the date on which the instruments of ratification are exchanged and shall thereupon have effect:
§
(a) in the United Kingdom:
§
(i) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6 April 1978;
§
(ii) in respect of corporation tax, for any financial year beginning on or after 1 April 1978;
§
(iii) in respect of development land tax, for any realised development value accruing on or after 1 April 1978; and
§
(iv) in respect of petroleum revenue tax, for any chargeable period beginning on or after 1 January 1978;
§
(b) in Switzerland: for any taxable year beginning on or after 1 January 1978.
§
(3) Notwithstanding the provisions of paragraph (2), the Convention shall have effect in respect of any dividend paid on or after 6 April 1975 to which paragraph (3) of Article 10 applies.
§
(4) Subject to the provisions of paragraph (5) the Convention between the United Kingdom of Great Britain and Northern Ireland and the Swiss Confederation for the avoidance of double taxation with respect to taxes on income signed at London on 30 September 1954, as amended by the Protocol signed at London on 14 June 1966 and by the Supplementary Protocol signed at London on 2 August 1974, (hereinafter referred to as “the 1954 Convention”), shall terminate upon the entry into force of this Convention and thereupon cease to have effect in respect of taxes to which this Convention, in accordance with the provisions of paragraph (2), applies.
§
(5) Where any provision of the 1954 Convention would have afforded any greater relief from tax any such provision as aforesaid shall continue to have effect:
§
(a) in the United Kingdom, for any year of assessment or financial year; and
§
(b) in Switzerland, for any taxable year beginning, in either case, before 1 January 1979.
§
(6) This Convention shall not affect any Agreement in force extending the 1954 Convention in accordance with Article XXI thereof.
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(7) The Agreement of 17 October 1931 between the Government of the United Kingdom and the Swiss Federal Council for reciprocal exemption from taxation on profits or gains arising through an agency shall terminate upon the entry into force of this Convention.
Citation to select or copy

Switzerland / United Kingdom; HMRC, 1977 UK-Switzerland Double Taxation Convention as amended by the 2017 protocol; edition 1977 Convention amended by 1981, 1993, 2007, 2009 and 2017 Protocols; HMRC updated 29 September 2021; article 28; English; unreviewed source text, current applicability unverified; /editions/ch-gb-1977-hmrc-amended-2017-html-v1/en/articles/article-28/

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Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

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Source & edition

HMRC, 1977 UK-Switzerland Double Taxation Convention as amended by the 2017 protocol

  • Official online text · retained capture Official source website ↗

    SHA-256 47363996866f352e121f3af31a77eac604d566eab9b948ff9a62bb11114ce474

    Digest scope: retained online-source capture; no PDF binary verification

Edition
1977 Convention amended by 1981, 1993, 2007, 2009 and 2017 Protocols; HMRC updated 29 September 2021
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Signature
1977-12-08

Languages recorded in source metadata: English. This is not a promise of available text or a translation.

Edition notes and known limitations

Official HTML text capture, not Original PDF; human wording and current-law certification not claimed.

Block IDs are navigation aids, never invented legal paragraph numbers. Native extraction can flatten ordered-list styling; only printed source labels are retained.

Complete preamble, closing and all supplied integral protocol/notes are retained separately and searchable within this source.

Publisher date discrepancy retained: amended-publication introduction says 2017 Protocol entered into force 16 July 2019; HMRC country index says 19 July 2019. No protocol entry-into-force date asserted in structured dates.

This is the 1977 Convention, not the older 1966 publication.

Source authority, text completeness and currentness still require human review.

2017 Protocol entry-into-force date differs between HMRC publication and index. do not assert a structured protocol entry-into-force date; wording preserved

Retained metadata & integrity record

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