SCHEDULES

SCHEDULE 36U.K.Agreement between UK and Switzerland

PART 3U.K.The future: income tax and capital gains tax

Effect of relevant certificateU.K.

15(1)The effect of the relevant certificate depends on whether P makes an election under paragraph 16 in respect of the underlying account for the applicable year.U.K.

(2)“The applicable year” is the tax year for which P is liable to income tax or, as the case may be, capital gains tax on the cleared amount.

(3)If P makes an election, the transferred sum is to be treated as if it were a credit allowable against the income tax or, as the case may be, capital gains tax due from P for the applicable year.

(4)If P does not make an election, P ceases to be liable to income tax or, as the case may be, capital gains tax on the cleared amount.

(5)Sub-paragraph (4) is to be read in accordance with paragraph 7.

(6)Where P ceases to be liable to tax on the cleared amount, P also ceases to be liable to any ancillary charge directly connected with that amount.