Liechtenstein Disclosure Facility (LDF) - HMRC Restricts Favourable Terms

On 14 August 2014 HM Revenue & Customs ('HMRC') announced a number of changes to the terms of the LDF affecting the ability of certain taxpayers who are not already registered to benefit fully from the advantageous terms.

Since its introduction in 2009, the LDF has offered UK taxpayers the opportunity to regularise their tax affairs on favourable terms including a reduced assessment period (back to 6 April 1999 instead of the normal 20 year period), the ability to apply a single composite rate of 40% or 50% depending on the tax year (enabling taxpayers to avoid paying inheritance tax that would otherwise be due), a generous penalty regime and immunity from prosecution. Since the launch of the LDF in 2009, more than 5,700 individuals have made disclosures and the facility has raised over £1bn.