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The Double Taxation Relief (Taxes on Estates of Deceased Persons and Inheritances) (Switzerland) Order 1994
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- 1994 No. 3214
- SCHEDULE
- Article 9
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Article 9Elimination of double taxation
(1) Where under this Convention the United Kingdom imposes tax on an event by reference to property:
(a)which may be taxed in Switzerland in accordance with Article 5, 6 or 7, or
(b)which may be taxed in the United Kingdom in accordance with paragraph (2), (3) or (4) of Article 8,
the United Kingdom shall allow against so much of its tax (as otherwise computed) as is attributable to such property a credit (not exceeding the amount of the tax so attributable) equal to so much of any tax imposed in Switzerland in connection with the same event as is attributable to such property.
(2) Subject to paragraph (3) of this Article, where the deceased was domiciled at the time of his death in Switzerland, Switzerland shall exempt from tax any property which, in relation to the same event and in accordance with Article 5, 6 or 7, may be taxed in the United Kingdom.
(3) Where any property is exempted from tax by any provision of this Convention, it may nevertheless be taken into account in computing the tax on other property or in determining the rate of such tax.
(4) For the purposes of this Article, tax is imposed in a Contracting State if it is chargeable under the law of that State and duly paid.
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