No relief on Swiss contributions

The taxpayer had dual British-Swiss nationality and had been UK-resident for tax purposes since 1969.

In the period of 1995 to 2009 she made voluntary contributions to OASI a Swiss national pension scheme from her UK after-tax income. She claimed UK tax relief on the payments which HMRC denied.

The First-tier Tribunal considered the conditions in article 18 of the UK/Switzerland double taxation agreement under which tax relief would be allowed in the UK on pension contributions to a Swiss scheme.

One condition was that the Swiss pension scheme must be accepted by the Revenue as generally corresponding to a pension scheme recognised as such for tax purposes.

It found there was no evidence to show HMRC had recognised the OASI as a pension scheme for UK tax purposes and therefore no UK tax relief was due.

The tribunal also agreed with the Revenue...