It was a busy month with 10 new statutory instruments and Explanatory Memorandums published by HMRC dealing with Double Tax Agreements or International Tax Enforcement matters with countries ranging from Singapore to Austria.

Included in the mix is The Double Taxation Relief and International Tax Enforcement (Switzerland) Order 2010. The Order brings into effect arrangements set out in the two Protocols made by the UK Government and the Swiss Federal Council.

The Protocols update the mutual agreement procedure and exchange of information articles in the Convention to bring them into line with the new international standards for mutual agreement procedure and exchange of information as set out in the Model Tax Convention on Income and on Capital published by the OECD. The Order will enter into force when both countries have completed the necessary steps.

However, this Order does not take account of the negotiations opened late October which reaffirmed the willingness of the UK and Switzerland to further intensify cooperation in financial and tax matters and to strengthen long-term legal security for market participants. This was covered in the November issue of tax.point.

By signing that declaration, the countries agreed to initiate negotiations on the expansion of cross-border cooperation in tax matters and improved market access for banks. Negotiations will be based on the exploratory talks conducted by a joint working group in recent months. Negotiations will commence as soon as both governments have issued their respective mandates and are expected to commence at the beginning of 2011.