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HMRC are busy reminding taxpayers with Swiss accounts that they only have until 1 January to make a full disclosure of their Swiss assets. The rather stark alternative is to suffer the one-off “regularisation payment” and fall into the withholding tax regime going forward.

One important nuance to the Swiss deal, however, is that it provides no protection from investigation by HMRC despite the potentially punitive tax charges.

Those with Swiss accounts therefore need to decide on a route forward in the near future. Ironically, one of the options may be to use the ongoing Liechtenstein Disclosure Facility (LDF) which may prove less costly in overall terms, and critically also provides protection from further investigation.

Those affected can contact us to discuss their circumstances an appropriate approach to bring their affairs up to date.