We've recently been seeing an increase in work using the
Liechtenstein Disclosure Facility (LDF), which we believe could be
useful for a wide range of clients and for a variety of
reasons.
What is the LDF?
The Liechtenstein Disclosure Facility (LDF) was negotiated
between HMRC and the Liechtenstein authorities and is in all but
name, a tax amnesty. It is open to all UK residents whether
domiciled or non-domiciled with undeclared offshore liabilities and
in respect of assets anywhere in the world. There need not be a
pre-existing link with Liechtenstein as the necessary link can be
simply created.
Advantages of the LDF
Advantages include the maximum penalty being fixed at 10% of the
outstanding tax plus interest, which is extremely favourable
compared with an involuntary tax investigation where HMRC may seek
a minimum 30% rising to 100%. Other advantages are immunity from
prosecution where full disclosure is given (and providing funds do
not come from wider
