United Kingdom

Liechtenstein Disclosure Facility (LDF) 

The LDF allows taxpayers to make a disclosure of tax irregularities connected with offshore bank accounts and structures held anywhere in the world on unique terms.
Contact us for a free, confidential, no obligation discussion
    Please call our helpline on 0800 970 9690 for a free, confidential, no obligation discussion

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 1.91 MB). 


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.


The LDF will close to new registrations after the end of 2015.  A tougher “last chance” disclosure facility will be offered between 2016 and mid 2017, with penalties of at least 30% (instead of 10% in the LDF) and no guaranteed immunity from prosecution.  This coincides with the provision of tax information under the Inter-Governmental Agreements in 2016 and the Common Reporting Standard from 2017.  We expect that when all facilities expire HMRC will intensify the number of investigations and those who have not disclosed will be penalised heavily, including criminal prosecutions in appropriate cases.


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) was available from 1 September 2009 and will run until the end of 2015. It is available for those with undisclosed tax liabilities connected with:


  • existing assets in Liechtenstein as at 1 September 2009. 
  • overseas assets outside of Liechtenstein but who acquired an asset or an interest in an asset in Liechtenstein anytime between 2 September 2009 and the end of 2015.


Offshore structure trustees and directors  can also participate in the LDF where UK tax liabilities arise regarding the structure, for example, of Inheritance Tax.


Taxpayers will no longer be able to benefit from the fixed 10% penalty (for periods to 5 April 2009), tax liabilities limited to the period from 6 April 1999 and the Composite Rate Option (CRO) which can eliminate certain liabilities (such as IHT) in return for taxing income and gains at 40% rather than calculate actual liabilities, where:


  • There is no disclosure of new information (e.g. Disclosure of Tax Avoidance Scheme cases)
  • The issue being disclosed is already subject to an intervention that began more than 3 months before the application to enter the LDF
  • There is no substantial connection between the liabilities being disclosed and the offshore asset held by the taxpayer on 1 September 2009


The LDF is only available until the end of 2015 so it is important to act now.
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.