UK-Switzerland Double Taxation Agreement: Who Taxes What

The UK-Switzerland double taxation agreement is the 1977 Convention between the two countries, last amended by a protocol signed in 2017. It decides which country can tax your income and gains when you live in one and have income from the other, and how the other country gives relief so the same income isn't taxed twice.

The double taxation agreement UK-Switzerland residents rely on taxes pensions, interest and royalties only where you live, and rent and property gains where the property is. Dividends can be taxed in both, with the source country limited to 15%. Pension lump sums are taxed only where the scheme is.

This guide goes through the treaty article by article, in both directions, and explains how to claim.

If you'd like this checked for your own situation, see our international tax advice.

What is the UK-Switzerland double taxation agreement?

When was it signed, and is it still current? The Convention was signed on 8 December 1977 and came into force on 7 October 1978. It has been amended by protocols signed in 1981, 1993, 2007, 2009 and 2017.

The 2017 protocol came into force on 19 July 2019. In the UK it applies to Income Tax and Capital Gains Tax from 6 April 2020, and in Switzerland from 1 January 2020. It added an anti-abuse rule, Article 27A, which denies a benefit where getting it was a main purpose of an arrangement. GOV.UK shows no later protocol at the time of writing.

👉 GOV.UK: Switzerland tax treaties

👉 GOV.UK: 1977 UK-Switzerland Double Taxation Convention as amended by the 2017 protocol

Which taxes does it cover? Under Article 2, UK Income Tax, Corporation Tax and Capital Gains Tax, and Swiss federal, cantonal and communal taxes on income, including capital gains. It doesn't cover:

• Swiss wealth tax. The treaty covers taxes on income only, and HMRC doesn't give credit for federal, cantonal or communal wealth taxes.

• Inheritance tax. A separate UK-Switzerland convention, in force since 7 March 1995, deals with that.

• National Insurance and Swiss social security. These fall under the UK-Switzerland Convention on Social Security Coordination, fully in force since 1 October 2023.

For how treaties work in general, see UK double tax treaties.

Who is resident under the treaty?

What if both countries treat you as resident? Each applies its own rules first, which for the UK means the Statutory Residence Test. If you're resident in both, Article 4(2) applies the tie-breaker tests in order: permanent home, centre of vital interests, habitual abode, then nationality. See our guide to dual tax residency.

Does the treaty mention Swiss lump-sum taxation? No. Article 4(1) only excludes people taxed in a country solely on income from sources there. A Swiss federal circular lists seven treaties that require a "modified" lump-sum basis before benefits can be claimed, and the UK's isn't one of them. Get your position confirmed before you claim.

Article 27(1) is a remittance clause. Where a UK resident was taxed on Swiss income only when it was brought to the UK, Switzerland gives treaty relief only on the amount remitted. The UK's remittance basis only covers income that arose before 6 April 2025, so the clause now matters only for that older income.

UK-Switzerland double tax treaty: who taxes what?

Which country taxes each type of income? The treaty gives one of three answers: only the country you live in, only the source country, or both, with relief where you live.

Image 1 — Swiss resident with UK income: who taxes what

Taxing rights under the UK-Swiss tax treaty

Employment: pay for work done in the other country can be taxed there. It stays taxable only where you live if you're present in the other country for no more than 183 days in its fiscal year, your employer isn't resident there, and the cost isn't borne by a branch there. For work in the UK, that is the UK tax year. Article 15 also covers share option gains.

Other gains: Article 13(6) keeps the UK's right to tax a person who is a resident of the UK at any time in the tax year of the disposal, so in a year you leave or arrive the treaty alone doesn't stop UK tax. The temporary non-resident rules can also apply if you return.

Government service: a UK civil service, armed forces or local authority pension is taxable only in the UK, unless you're both resident in Switzerland and a Swiss national.

👉 HMRC manual: Switzerland treaty summary (DT18104)

Swiss 35% withholding tax on dividends and interest

How much Swiss tax should a UK resident bear? Switzerland deducts anticipatory tax (Verrechnungssteuer) at 35% from dividends and interest. The treaty allows Switzerland 15% on dividends and nothing on interest. You can reclaim 20 of the 35 points on a dividend, and all of it on interest.

You claim from the Swiss Federal Tax Administration on Form 86 (United Kingdom). The right to a refund expires three years after the end of the calendar year in which the income fell due. HMRC can confirm your UK residence on the form or issue a certificate of residence.

👉 Swiss Federal Tax Administration: United Kingdom treaty forms, including Form 86

👉 Swiss Federal Tax Administration: Claim to refund of Swiss anticipatory tax

In the UK, the dividend is taxed in full and you claim Foreign Tax Credit Relief, limited to the 15% treaty rate, not the 35% deducted. See our guide to UK tax on foreign income.

Image 2 — Swiss 35% withholding tax and the treaty reclaim

Worked example: Anna's Swiss dividend

• Anna is UK resident and a higher rate taxpayer. In 2026/27 she receives a Swiss dividend of £10,000. Her £500 dividend allowance is used elsewhere.

• Switzerland deducts 35%, which is £3,500. She receives £6,500.

• The treaty limit is 15%, which is £1,500. She reclaims £2,000 from Switzerland on Form 86.

• UK tax at 35.75% is £3,575. Credit for Swiss tax is £1,500, so she pays HMRC £2,075.

• Total tax is £3,575. Without the Swiss reclaim it would be £5,575.

In the other direction, the UK doesn't deduct tax from ordinary company dividends paid to Swiss residents. Property income dividends from UK real estate investment trusts have 20% deducted, reduced to 15% by a refund claim.

UK Switzerland tax treaty: pension income

Which country taxes a UK pension if you live in Switzerland? Under Article 18(1), private and workplace pensions and the State Pension are taxable only in Switzerland. Once HMRC accepts your claim, the payer uses tax code NT, meaning no tax is deducted.

Lump sums are different. Under Article 18(2), a lump sum from a pension scheme established in the UK is taxable only in the UK, under UK rules. HMRC's notes say this covers most lump sums from most UK schemes. Our guide to the tax treatment of pension income covers the UK side.

What about Swiss pensions paid to a UK resident? Regular pensions from private-sector Swiss occupational schemes (pillar 2) and tied private schemes (pillar 3a) are taxable only in the UK under Article 18(1). The Swiss treaty overview shows no Swiss tax at source on them for UK residents.

Capital withdrawals work the other way. Switzerland deducts tax at source, and its overview shows no refund for UK residents. That matches Article 18(2), under which a lump sum from a pension scheme established in Switzerland is taxable only there. The treaty ties "pension scheme" to retirement benefits from employment or self-employment, so have the UK treatment of your arrangement confirmed before you withdraw.

Property: rent and gains in each direction

Who taxes a UK rental property owned by a Swiss resident? The UK, under Article 6. Your agent or tenant deducts basic rate tax under the Non-resident Landlord Scheme unless HMRC approves gross payment. Article 27(4) gives Swiss residents UK personal allowances, except (Article 27(6)) where their only UK income is dividends, interest or royalties.

Gains on UK land, and on shares in companies holding mainly UK land, are taxable in the UK under Article 13. You report the disposal within 60 days of completion, even if no tax is due. See non-resident capital gains tax. Switzerland exempts the rent and the gain (for land-rich shares, only if UK taxation is shown), but can count them when setting your rate.

For Swiss property owned by a UK resident, Switzerland taxes the rent and any gain. The UK taxes them too and gives credit for the Swiss income taxes, but not wealth tax.

How double taxation is relieved, and how to claim

Does the treaty apply automatically? No. Article 22 sets the method: the UK gives a credit for Swiss tax, and Switzerland generally exempts income the UK may tax, with a separate relief for dividends. You still have to claim.

• Swiss resident with a UK pension, annuity, interest or royalties. Use HMRC's Form Switzerland-Individual, not the general DT-Individual. It goes to the Swiss tax authorities, who certify your residence and forward it to HMRC.

• Swiss resident who files a UK tax return. Claim with the HS304 form and the SA109 residence pages.

• Resident in both countries. Claim treaty residence in Switzerland with the HS302 form.

• UK resident with Swiss income. Report it on the foreign pages of your return and claim Foreign Tax Credit Relief, limited to the treaty rate.

👉 HMRC form: Double Taxation: UK-Switzerland (Form Switzerland-Individual)

👉 HMRC helpsheet: HS304 Non-residents tax relief under double taxation agreements

👉 GOV.UK: Apply for a certificate of residence or letter of confirmation

👉 GOV.UK: Tax on foreign income: if you're taxed twice

Worked example: Claire in Geneva

• Claire is British, lives in Geneva and is resident only in Switzerland. She has a UK private pension of £30,000, a UK civil service pension of £10,000 and UK rental profit of £8,000.

• Private pension: taxable only in Switzerland. She claims on Form Switzerland-Individual and it's paid under code NT.

• Civil service pension: taxable only in the UK, because she isn't a Swiss national. Rental profit: taxable in the UK.

• Her UK taxable income is £18,000. After the £12,570 personal allowance, £5,430 is taxed at 20%, giving UK tax of £1,086.

• Switzerland exempts the civil service pension and the rent, but can count them when setting her rate.

Common mistakes with the UK-Swiss tax treaty

• Using the wrong form. Swiss residents use Form Switzerland-Individual, not DT-Individual, and it needs Swiss certification.

• Leaving 35% in Switzerland. The UK gives credit for 15% on dividends and none on interest. The rest has to be reclaimed from Switzerland within three years.

• Treating a lump sum like a pension. Regular pensions are taxed where you live. Lump sums are taxed only where the scheme is established.

• Thinking treaty residence ends UK residence. The tie-breaker only decides how the treaty shares taxing rights. You're still UK resident under UK law and still file a UK return.

Frequently asked questions

Is there a double taxation agreement between the UK and Switzerland?

Yes. The UK-Switzerland Double Taxation Convention was signed in 1977 and has been amended by five protocols, most recently in 2017. It covers Income Tax and Capital Gains Tax in the UK, and federal, cantonal and communal income taxes in Switzerland.

How is a UK pension taxed if I live in Switzerland?

Private pensions, workplace pensions and the State Pension are taxable only in Switzerland under Article 18. Lump sums from a UK pension scheme are taxable only in the UK. Government service pensions stay taxable in the UK unless you're a Swiss national living in Switzerland.

Can I reclaim Swiss withholding tax as a UK resident?

Yes, in part. Switzerland deducts 35% from dividends and interest. The treaty limits Swiss tax to 15% on dividends and nil on interest, so you can reclaim the excess from the Swiss Federal Tax Administration on Form 86, within three years after the end of the year the income fell due.

Do I pay UK tax on UK rental income if I live in Switzerland?

Yes. The treaty lets the UK tax income from UK property, and tax is usually deducted under the Non-resident Landlord Scheme. Swiss residents can generally claim the UK personal allowance. Switzerland exempts the rent but can count it when setting your tax rate.

Which form do Swiss residents use to claim UK tax relief?

HMRC's Form Switzerland-Individual, which covers UK pensions, purchased annuities, interest and royalties. The Swiss tax authorities certify your residence and send it on to HMRC. If you file a UK tax return, you claim with the HS304 form and the SA109 pages.