HMRC has received £342m from Switzerland as a result of the Swiss-UK tax deal which came into force on 1 January.
This payment is being made by Swiss banks in advance of the one-off charge being levied on their customers.
Under the deal, the Swiss are taxing the bank accounts of UK citizens and transferring the money directly to the Treasury without revealing the identity of account holders.
The £342m is just the first instalment, however the Revenue is expecting the deal to add £5bn of previously unpaid tax to their coffers.
Current and future tax liabilities in Swiss accounts will be covered by a new withholding tax of 48% of income.
Swiss authorities will now routinely notify HMRC about British holdings, meaning those with Swiss assets, even undeclared, will find themselves under the Revenue's glare.
In October 2012, Britons with Swiss accounts and taxable assets were urged by HMRC and tax advisers to come forward to HMRC or face the tax.
Commenting on the initial payment, exchequer secretary David Gauke said: “Our agreement with the Swiss government will deliver around £5bn of previously unpaid tax to the UK.
“Offshore evasion costs the UK billions of pounds every year and we are determined to tackle it. One of the ways is through information exchange and this agreement makes it easier for HMRC to obtain information about UK taxpayers suspected of hiding money in Switzerland.”
However, PKF partner John Cassidy thinks the payment is being marketed as something that it's not.
"It is actually CHF500m [around £340m] that has been paid by the banks, not by their customers. Provision for that payment has been in the UK-Swiss agreement since day one," he said.
"It is an upfront payment by the banks collectively to demonstrate their willingness to implement and enter into the spirit of the agreement. Clearly the banks will hope to recoup it from withholding taxes levied on their clients under the agreement, but at present it is merely a payment on account made by the banks not linked to their customers, compliant or otherwise."
A number of options are available to residents with Swiss assets according to tax advisers Gabelle, including:
- move funds out of Switzerland by 31 May 2013
- use the Liechenstein Disclosure Facility, which will run until April 2016
- make a voluntary disclosure to HMRC
- pay a flat rate tax for the past and withholding taxes going forward
- opt out and claim the remittance basis charge
Guidance was also published in November 2012 by HMRC for those potentially affected.