The number of the legal instrument (or, before 1948, the number of legislation and regulations) attached to the provisions of the agreement; and to conclude a new agreement to avoid double taxation and prevent tax evasion with respect to discounts on deceased persons and donations; (3) The Two Contracting States impose on the same date taxes on property which, under U.S. law, would be considered assets equivalent to a trust or trust and, under United Kingdom law, as property included in a transaction – Double taxation should be avoided as follows: 4) a contracting state`s enterprise: Whose capital is held or controlled, directly or indirectly, by one or more residents of the other State party, may not be subject, in the first state, to a tax or requirement that is different or more burdensome than the taxation and related requirements to which other similar enterprises of the first state may be or may be subject. If, in both countries, the assets are taxable under one of the above articles, the convention resolves the possible double taxation: by providing that the United Kingdom is liable for Swiss tax on real estate and commercial property in Switzerland, as well as on ships, aircraft and other property for which Switzerland has primary tax rights; providing Switzerland with tax revenues that exempt real estate and commercial property in the United Kingdom as well as ships and aircraft from UK companies (Article 9). Most EU Member States impose taxes on the death of a person. Some Member States impose a tax on heirs, while others apply a tax on the basis of the estate. In both cases, the tax liability is determined on the basis of a large number of relevant factors (i.e. the residence, residence or nationality of the deceased and/or the beneficiary) and/or the location of the property. In some cases, tax authorities may apply these factors at the same time. Factors can also have different meanings from one country to another. This situation can lead to a double, if not repeated, taxation of the same assets in different Member States. Many Member States have introduced mechanisms in their national legislation to avoid double taxation of estates. However, such mechanisms would not, in most cases, allow for a complete exemption from double taxation. Apart from these limited national discharge provisions, there are few solutions to double taxation, as Member States have concluded very few bilateral tax treaties to avoid double taxation on inheritance and inheritance tax.

In 2011, after considering the effects of various options to address existing problems, the Commission made a recommendation to reduce double taxation of estates. This recommendation consisted of proposals for Member States on how to amend their existing national provisions to reduce double taxation. These changes could include the introduction of tax credits on taxes paid in another Member State or the exemption from the national tax base for certain elements of foreign property. The Commission also recommended a regulation on tax duties (i.e.: