I have a life insurance client that has Swiss equity investments that are linked to its pension business liabilities. The client's claim for the 0% rate of withholding available to UK pension schemes receiving dividends from companies resident in Switzerland under the UK Swiss double taxation treaty was rejected by the Swiss authorities The client pointed out that this situation was specifically covered in the memorandum of understanding between the UK and Switzerland dated 12 February 2008 .
It's quite hard to find this on the web so I have included a link below
You might think that the memorandum makes it entirely clear that linked pension business should obtain the 0% rate but the Swiss authorities are apparently still disputing the claim. If anybody else is having similar problems and would like to get in touch with my client than please drop me a line.
richard.bentley@bentleyforbesconsulting.co.uk
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