The United Kingdom (UK) is an important economic and political partner of Switzerland. Relations between the two countries are also close in the financial sector. The two countries hold regular financial dialogues which serve to establish and maintain privileged contacts with the authorities involved in financial matters.
On 23 June 2016, the UK electorate voted in favour of leaving the European Union (EU). This decision came into force on 31 January 2020 on the basis of the withdrawal agreement negotiated between the EU and the UK. The transition period set out in the withdrawal agreement expires on 31 December 2020. Thereafter, the UK will cease to be part of the EU internal market and the customs union, and will no longer be bound by EU law.
To date, relations between Switzerland and the UK have been largely based on bilateral agreements between Switzerland and the EU. This is also true of the financial sector. With Brexit (i.e. after the end of the transition period agreed), these agreements will no longer apply to the UK. For this reason, in October 2016, the Federal Council launched its "Mind the gap" strategy, in order to best ensure and, if need be, extend the existing reciprocal rights and obligations between the two countries.
During the transition period, the EU's third-country agreements, such as the bilateral agreements between it and Switzerland, remain applicable to the UK. Therefore, nothing changes between Switzerland and the UK during this period. In order to provide a seamless continuation of the current regulations in the financial sector, Switzerland and the UK signed an agreement on 25 January 2019 on direct insurance other than life assurance (UK-Swiss DIA). Like the insurance agreement with the EU, this agreement allows non-life insurance companies (e.g. household and travel insurers) to operate branches in the other country.
After the end of the EU-UK transition period, the Swiss-UK DIA will come into force, seamlessly replacing the current legal basis in the area of insurance.
The Swiss and UK financial market supervisory authorities were involved in the work on the "Mind the gap" strategy and, for their part, took the necessary steps to ensure the existing reciprocal rights and obligations at supervisory authority level (e.g. by adapting supervision-related cooperation agreements).
On 30 June 2020, Federal Councillor Ueli Maurer and the British Chancellor of the Exchequer, Rishi Sunak, signed a joint statement on intensified future cooperation between the two countries in the area of financial services, thus underlining their shared intention to deepen financial relations. The envisaged agreement should enable cross-border market access for a wide range of financial services relating to insurance, banking, asset management and capital market infrastructure.
In the area of taxation, a double taxation agreement (DTA) exists between Switzerland and the UK. The DTA has been revised several times, most recently by means of a protocol of amendment which entered into force on 19 July 2019.
In the area of administrative assistance in tax matters, the UK, like Switzerland, is a contracting party to the OECD/Council of Europe Multilateral Convention on Mutual Administrative Assistance in Tax Matters. This is the basis on which the two countries exchange information on request.
Switzerland and the EU signed an agreement on the AEOI in 2015. Since autumn 2018, data has been exchanged between Switzerland and the United Kingdom on this basis. During the transition period, the bilateral agreements between the EU and Switzerland, remain applicable to the UK. After the end of the EU-UK transition period, the AEOI is expected to continue from 1 January 2021 on the basis of a Multilateral Competent Authority Agreement (MCAA).
Last modification 23.12.2020