(a) he is considered a resident of the state in which he has a permanent homeland; if he has a permanent homeland in both states, he is considered a resident of the state with which his personal and economic relations are more closely linked (vital focus); The protocol also provides that the herendation will be included in the agreement. Recipients of an undisclosed Swiss bank account must either pay inheritance tax or give their consent to the dive permit to be disclosed to the British authorities. This agreement largely follows the OECD`s model of agreement and Swiss policy in this regard. (b) arrangements have been made to allow the exemption from double taxation with regard to capital gains tax, corporation tax, income tax and similar taxes imposed by Swiss law; and (4) A company residing in Switzerland that derives dividends from a company domiciled in the United Kingdom is entitled, for Swiss tax purposes, to the same exemption that would be granted to the company if the dividend payer was established in Switzerland. 5. The provisions of paragraphs 1, 2 and 3 do not apply when the actual beneficiary of the dividends as a resident of a contracting state operates in the other contracting state, whose resident is the dividend distribution company, and provides independent personal services in that other state from a fixed base established in that state. and the shareholding for which dividends are paid is effectively related to such a stable institution or a fixed base. In this case, the provisions of Article 7 or Article 14 of Article 25.-1. All the information thus exchanged is treated as secret and cannot be disclosed to anyone other than those concerned with the taxation and collection of taxes covered by the Convention. No information can be exchanged that would reveal trade, trade, banking, industrial or professional secrets or business processes.

ARTICLE 23.-1) Nationals of one State Party should not be subject to a tax or obligation which, in the other State party, is different or heavier than the imposition and related requirements to which nationals of that other State are subject or may be subject in the same circumstances. (a) Swiss tax, either directly or by deduction, on profits, income or profits from taxable sources in Switzerland (with the exception, in the case of a dividend, of the tax payable for the profits on which the dividend is paid) is accepted as a credit to any UK tax. which is calculated by referring to the same benefits. , taxable income or profits on which Swiss tax is calculated; ARTICLE 26.-1) This Convention does not affect the tax privileges of diplomatic agents or consular officials under the general rules of international law or the provisions of specific agreements.