HMRC announce Liechtenstein Disclosure Facility
What is the Liechtenstein Disclosure Facility?
The Liechtenstein Disclosure Facility (LDF) offers a means for UK residents with unpaid tax to make disclosures to HM Revenue and Customs (HMRC) of tax irregularities where monies are (or have been) held in bank accounts anywhere in the world, or where overseas property has been bought using undeclared monies, or where offshore companies may have been used to evade tax.
What are the advantages of the LDF?
You can voluntarily disclose tax liabilities under the LDF between 1 September 2009 until 5 April 2016 and take advantage of the terms below:
- a 10 rather than 20 year maximum disclosure period (HMRC is allowed under domestic legislation to assess up to 20 years where deliberate behaviour is involved)
- a flat rate 10% penalty of the tax unpaid (or 20% where there has been a previous opportunity to make a disclosure under earlier facilities. Penalties for deliberate behaviour can be up to 100%)
- guaranteed immunity from prosecution for tax offences.
Who can use the LDF?
To take advantage of the LDF you do not need to have previously had a bank account or other investments in the principality of Liechtenstein, although if someone did then qualification is automatic. Equally you do not need to have ever had any complicated or sophisticated tax structure there in order to benefit from the LDF. However, in the absense of such 'qualifiers' you will need to establish "relevant property" in Liechtenstein, which can be done by opening bank account there now.
How can Crowe Clark Whitehill help you?
This is a specialist area where careful and expert handling of a disclosure is essential, if the full advantages of the LDF are to be gained and the pitfalls avoided. Crowe Clark Whitehill have contacts with a number of banks and Trust Companies in Liechtenstein to which confidential introductions can be made.
Why should you contact us?
We have a dedicated team of former tax inspectors, who have a significant amount of experience in dealing with complex offshore tax structure including foundations, anstalts and stiftungs.
Our specialist team can offer immediate support with a confidential free initial consultation.
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Call our helpline 020 7842 7200 for a free no obligation discussion or email investigations@crowecw.co.uk. Alternatively, please complete our enquiry form and one of our team will contact you.