SCHEDULES

C1SCHEDULE 36Agreement between UK and Switzerland

Annotations:
Modifications etc. (not altering text)

PART 2The past

Interest, penalties etc

9

1

Where, by virtue of this Part, P ceases to be liable to tax on a qualifying amount, P also ceases to be liable to any ancillary charge directly connected with that amount.

2

Where, by virtue of this Part, all or part of a one-off payment is treated as if it were a credit allowable against the tax due from P taking account of a qualifying amount, the credit may also be used to offset any ancillary charge directly connected with that amount.

3

Sub-paragraph (4) applies in the case of a qualifying amount that is part only of—

a

an amount of income on which income tax is charged,

b

a chargeable gain,

c

the value of property forming part of the value transferred by a chargeable transfer, or

d

the value of a supply on which VAT is charged.

4

The amount of any ancillary charge directly connected with that qualifying amount is determined by apportioning the ancillary charge directly connected with the income, gain or value on a just and reasonable basis.