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First, they can pay for the past a one-time fee based on the amount of assets held in Switzerland. The amount of tax is determined on the basis of a formal formula contained in the tax treaty. This formula takes into account the duration of the banking relationship and the difference between the initial amount and the final amount of the capital. With respect to banking relationships that already existed prior to January 1, 2003, the starting value of December 31, 2002 is taken into account. As a result, the individual capital burden ranges from 21% to 41% for the United Kingdom and 15% to 38% for Austria. These rates vary depending on the specific individual situation (the date the account was placed and the amount of assets deposited in the past and unreported). For Germany, they would be between 21 and 41%. With this transfer, the tax debt is considered permanently paid. Preliminary forecasts indicate that the average tax burden will vary by about 25% of the average asset over the period under review. The agreements use the “Rubik” model to deal with unreported billions of foreign customers in Swiss banks. For her part, Swiss Finance Minister Eveline Widmer-Schlumpf said she was ready to discuss “specific technical issues” but not to change the substance of the agreement. With regard to the regularisation of the past, tax treaties offer clients residing in Germany, Austria or the United Kingdom two types of regularizations of their existing banking relations in Switzerland. Withholding agreements with Germany, the Uk and Austria The European Union, however, says that these agreements violate EU savings tax rules and want to change them.

The agreement, rejected by the German Bundestag, stated similar conditions, i.e. residence in Germany as of 31 December 2010, Swiss account holders on 31 December 2010 and Swiss account holders on 1 January 2013. “I think that the German government has the means to avoid the failure of the project and thus avoid the humiliation of signing an agreement with a third country and getting screwed by Brussels. Tax expert Paolo Bernasconi says he expects Germany to ask for changes on some points that are not fully compatible with the EU, but are not all lost. “The chord is designed like the rubik cube with different blocks. When you remove a block, it doesn`t collapse. “And if it works with Germany, I imagine a lot of other countries might be interested in a similar agreement,” he said. The agreement with the United Kingdom has a signal value. After Austria and the experience of Germany, other countries, such as Spain, Italy or Greece, will probably be interested in this model. Indeed, tax treaties paraphrased by Switzerland involve high costs for Swiss banks, the retroactive payment of tax on assets deposited and unreported in Switzerland and weaken Swiss banking secrecy. With the agreements reached, Swiss banking secrecy is lower and takes different degrees depending on the country. Even if the EU approves these agreements, each country concerned still needs parliament`s approval. We had the example of Germany.

The French government has opposed such agreements that allow the taxpayer to be anonymous. As a result, these partner states and other non-signatory states (for example. (B) France could put pressure on Switzerland to automatically exchange information, compensating for the risk of lawsuits against Swiss banks and their employees, the withdrawal of the banking licence or the refusal of mutual assistance agreements with the country concerned.