United Kingdom

The Key Terms of the LDF at a Glance 

The Key Terms of the LDF at a Glance
 LDF  Normal practice
Timescale Available between 1 September 2009 and the end of 2015 20 years for most taxes – 1994/95 to 2013/14. Unlimited for Inheritance Tax liabilities.
Periods covered 6 April 1999 onwards including Inheritance Tax 20 years for most taxes - 1994/95 to 2013/14. 
Unlimited for Inheritance tax liabilities.
Guaranteed immunity from prosecution Yes, provided the funds are not derived from wider criminality (i.e. something other than tax evasion) No
Ability to speak to HMRC on a "no names" basis prior to making a disclosure Yes No
Able to participate if already under investigation by HMRC Yes, unless already under investigation for serious tax fraud (Code of Practice 9) or a criminal investigation has already started.  
Penalty on unpaid tax 10 percent to 5 April 1999 and 20% or 30% for 2009/10 and 2010/11; jurisdiction based thereafter Up to 100 percent but up to 200% if an overseas asset is involved
Able to calculate tax liability using a composite rate of tax Yes, to 5 April 2009 No
Interest on unpaid tax Yes Yes


Please call our helpline on 0800 970 9690 for a free, no obligation discussion.

Alternatively, please contact Derek Scott on derek.h.scott@kpmg.co.uk or 020 7311 2618.