Tax Disputes & Investigations

Liechtenstein Disclosure Facility (LDF)

In August 2009, HM Revenue & Customs (HMRC) launched the Liechtenstein Disclosure Facility (LDF) along with a new Tax Information Exchange Agreement (TIEA) with Liechtenstein. The UK and Liechtenstein governments signed a Memorandum of Understanding (MOU) aimed at preventing the evasion of UK tax (via Liechtenstein). In essence, the MOU contained a two-pronged approach: -

1. HMRC would offer a bespoke disclosure facility to allow UK taxpayers to regularise their affairs; and

2. Liechtenstein banks and fiduciary companies would commence a taxpayer compliance programme requiring that UK clients confirm that their UK tax affairs are in order. If not, then the clients would be asked to make a disclosure to HMRC. If a client does not confirm that they have fully complied with their UK tax requirements by 31 March 2015 then the Liechtenstein banks and/or fiduciary companies will end the relationship (i.e. close the account, structure etc).

The LDF runs until 31 March 2015. It allows UK taxpayers to regularise their affairs without fear of prosecution and offers a number of potential benefits that could lead to real tax savings!

The terms that are available under the LDF differ for those who already held funds/assets in Liechtenstein when the LDF was launched (see our FAQs for Existing Liechtenstein Account/Asset Holders) and those who didn't (but who now want to make a disclosure to HMRC via the LDF – see our FAQs for Offshore Account/Asset Holders held outside Liechtenstein for more information.). The facts of your case will determine which of the LDF's beneficial terms you will be able to secure. Specialist advice from OneE TDI is essential before any disclosure is made to HMRC.

The terms offered by the LDF are more beneficial than would normally be secured or negotiated with HMRC as part of any tax disclosure. Real 'tax savings' can be made. The best terms are available to those who voluntarily approach HMRC – so don't delay.

How can OneE TDI help?

The LDF offers taxpayers a real opportunity to bring their UK tax affairs up-to-date without fear of prosecution. Tax (plus a related reduction in interest charges and possible penalties) can also be saved. OneE TDI is currently representing a number of clients who are going through the LDF process and assisting Agents/Advisers and their clients as to how the LDF can work for them. We have successfully settled a number of cases where the clients involved have paid considerably less to HMRC than would potentially have been due. If required, we can also help clients to establish the 'relevant property' they require in Liechtenstein to allow them to apply to register for the LDF.

At the core of OneE TDI is a highly experienced team specialising in the management of all tax disclosures. We offer confidential, non-judgemental and invaluable advice and have a proven track record in successfully concluding matters with HMRC on behalf of our clients.

Please see the Testimonials kindly provided by our clients (or their accountants or lawyers), which confirm our levels of client service and expertise in this area.

How can I contact OneE TDI?

If you would like a free, confidential, no obligation discussion with us please contact either Gary Rowson or Mark Taylor on 0800 652 6156 or complete and submit the online form below.

Whilst we endeavour to provide informative and accurate information, the content on this site is for general information purposes only and should not be taken to constitute tax or legal advice which must always be tailored to individual circumstances. Please contact us if you would like to discuss matters.

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