SCHEDULES

SCHEDULE 36 U.K. Agreement between UK and Switzerland

PART 2 U.K. The past

Effect if P not eligible for clearance U.K.

8 (1) This paragraph sets out the effect of the Part 2 certificate if P is not eligible for clearance. U.K.

(2) The one-off payment is to be treated as if it were a credit allowable against the tax due from P taking account of qualifying amounts.

(3) The one-off payment is to be applied for the purposes of sub-paragraph (2)—

(a) in the order specified in sub-paragraph (4), and

(b) subject to that, in the way that produces the most beneficial outcome for P.

(4) The order is—

(a) first, for VAT,

(b) then, for income tax,

(c) then, for capital gains tax, and

(d) finally, for inheritance tax.