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.