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Old 14.10.2019, 02:55
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Re: How does it work with taxes already paid in UK?

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That is correct. I am not referring to corporate taxes but personal ones. Corporate taxes were paid much earlier, prior to liquidation of the company.

I have not seen anywhere to suggest that the Zurich tax office is attempting to value the company. So far, everything is taken at book value (it is a private limited company after all).

FYI, the independent liquidator distributed the liquidation proceeds after the liquidation was completed.

What is critical for me is that I am not paying twice the amount of taxes on this. The amount I paid to the HMRC, appears to me, to exceed the amount quoted by the Zurich tax office. Taking a simplistic view on the tax treaty, I should not pay any more than I already did to the HMRC.
As I said you really need to talk to a tax advisor and with such limited information all I can do is guess... I expect the Swiss authorities are using the nominal value of the shares and assuming everything else distributed by the liquidator is income, which it is not. One approach would be to value the shares according to Swiss tax rules which would be several magnitudes great and use that value to demonstrate that the liquidation distribution could be nothing other than capital and not subject to Swiss income tax.

Iíve used these guys in the past for this kind of thing: taxexpert.ch. But the partner I knew has retired and Iím no longer in the business either.
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