United Kingdom

Liechtenstein Disclosure Facility (LDF) 

There is now a unique opportunity, not seen in previous disclosure facilities and not likely to be repeated in the future, for taxpayers to make a disclosure of tax irregularities connected with offshore bank accounts and structures held anywhere in the world on favourable terms.
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    Provided a Liechtenstein connection is established the Liechtenstein Disclosure Facility (LDF) can be used as an umbrella for the disclosure of any tax liability connected with an overseas asset.  It is not necessary for all overseas assets to be transferred to Liechtenstein to qualify for the LDF.  


    Please read on and use the menu to the right for further details or download our UK client briefing sheet (PDF 648 KB). 


    What are the unique benefits of the LDF?


    • A guaranteed immunity from prosecution for tax related offences.
    • Ability to have initial "no names” discussions with HMRC, prior to making a disclosure. 
    • Tax liability limited to the period from 6 April 1999 as opposed to the normal 20 year rule.
    • There is no time limitation for the recovery of undisclosed Inheritance Tax liabilities.  Under the Liechtenstein Disclosure Facility (LDF) Inheritance Tax will also be limited the period from 6 April 1999, which is a significant concession in relation to inherited wealth. 
    • A simplified composite rate of tax (the CRO) which, if used in the right circumstances, can reduce liabilities even further.


    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.

    Who is eligible to participate?

    The Liechtenstein Disclosure Facility (LDF) is available from 1 September 2009 and will run until 5 April 2016.  It is open from:


    • 1 September 2009 for those with undisclosed tax liabilities connected with existing assets in Liechtenstein as at 1 September 2009.  
    • 1 December 2009 for those with undisclosed tax liabilities connected with overseas assets outside of Liechtenstein but who acquired an asset or an interest in an asset in Liechtenstein anytime between 2 September 2009 and 5 April 2016.


    Trustees and Directors of offshore structures can also participate in the Liechtenstein Disclosure Facility (LDF) where UK tax liabilities arise in respect of the structure, for example, Inheritance Tax.


    A diverse range of people are taking advantage of the LDF.

    Although the LDF is available until 5 April 2016 it is important to start taking action now.  Please see our important notes on timing of disclosures under the LDF for further detail.

    Please note you can access further information on the LDF via the links in the right column of this page, these include a detailed frequently asked questions page.