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Steps to take when moving to Switzerland - Finance Valley Lake ...

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Tax - UK drivers for migration<br />

• Push fac<strong>to</strong>rs<br />

– Increase in <strong>to</strong>p personal income tax rate <strong>to</strong> 50%<br />

– Personal allowance and tax relief on pension contribution clawbacks<br />

– Changes <strong>to</strong> residency rules and erosion of non-dom privileges<br />

– Handling of investigations in<strong>to</strong> the industry<br />

– Increasing quantity of anti-avoidance legislation (TOAA & DRR)<br />

– IME (investment manager exemption) - transfer pricing & the potential <strong>to</strong> tax an<br />

offshore fund in the UK<br />

• Pull fac<strong>to</strong>rs<br />

– Other jurisdictions have infrastructure, inves<strong>to</strong>r base, cost/other benefits<br />

– Other jurisdictions have significant tax advantages, e.g. level of income subject <strong>to</strong><br />

tax minimal and defined in advance rulings, low tax rates, no on-shore tax<br />

implications for offshore fund product<br />

– <strong>Switzerland</strong> forming clusters of fund managers in places like Pfäffikon around<br />

Zurich and Geneva

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