Tax Investigation Specialists

WLHTax - Liechtenstein Disclosure Facility (LDF)


In September 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). The MOU contained the following:

  • HMRC would offer a bespoke disclosure facility to allow UK taxpayers to regularise their affairs; and
  • 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 5 April 2016 then the Liechtenstein banks and/or fiduciary companies will end the relationship (i.e. close the account(s)).

WLH Tax would like to emphasise that taxpayers are perfectly entitled to operate bank and investment accounts in offshore jurisdictions. However, if an individual is resident and domiciled in the UK, they have an obligation to disclose any income that has arisen in such accounts on their UK Tax Return. If you have failed to disclose the income that has arisen on your offshore bank or investment accounts and you believe that the income is liable to UK tax, WLH Tax would strongly recommend that you make a voluntary disclosure to HMRC under the LDF as soon as possible.

The LDF runs until 5 April 2016. It allows UK taxpayers to regularise their tax affairs without fear of prosecution and offers a number of potential benefits that could lead to real and substantial 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 FAQ Section) and those who didn't (but who now want to make a disclosure to HMRC via the LDF – also see our FAQ Section 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 WLH Tax 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.

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. WLH Tax 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.

WLH Tax is highly experienced and specialises in the management of all tax disclosures. We offer confidential, non-judgemental and invaluable advice and have a proven track record of successfully concluding matters with HMRC on behalf of our clients.

Please visit the following pages for more information on the LDF:

How can WLH Tax help?

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Please call WLH Tax on +44 (0) 207 491 9690 or +44 (0) 207 491 9696 if you wish to discuss the LDF in greater detail.