The Liechtenstein Disclosure Facility

The Liechtenstein Disclosure Facility (LDF) is a tax disclosure facility for UK taxpayers. It is open to those with unpaid UK tax liabilities who had assets outside the UK (whether or not in Liechtenstein) as at 1 September 2009. It can be used to regularise their tax affairs on preferential terms, without fear of prosecution, without the usual penalties and without being ‘named and shamed’ by HMRC.

What are the advantages of using the facility? Set out in this briefing is a table of the key advantages of the LDF, compared with the normal rules if investigated by HMRC.

When calculating the actual tax liability, the taxpayer can opt to apply a flat rate of tax of 40 per cent, rather than working out the actual liability. This approach can save time and costs and can also result in significant inheritance tax savings in certain cases…