LDF and Swiss-UK Tax Agreement
already been used successfully by many people in the UK. Those who are fully eligible to participate
in the LDF are entitled to the following key benefits:
=" Under the LDF, the 'look back' period for undeclared tax of any sort goes back only to April
1999 (as opposed to the usual period of 20 years, or for an unlimited period in relation to in-
heritance tax) - therefore no tax is payable in respect of any liabilities arising before 1999;
" Taxpayers are given the option either to:
=" apply a single composite rate of tax at 40% (up to April 2009); or
" calculate actual liability using applicable annual tax rates and allowances
" Amaximum fixed penalty of just 1096 will be charged on unpaid taxes up to April 2009 (as
opposed to the usual starting penalty of 150%). A slightly higher penalty will be applied in re-
spect of tax years after April 2009, generally 20%.
" An assurance against criminal prosecution for tax offences in cases of full and accurate dis-
closure;
" no public "naming and shaming" in The Gazette and on HMRC:'s website. °°
Taxpayers who are prevented from utilising the LDF are effectively limited to those who (1) have
already been notified by HMRC that they are under investigation by HMRC or (2) do not have rele-
vant property in Liechtenstein at the time of applying for registration under the LDF. It is therefore
important that you maintain your relationship with us in Liechtenstein and that you do not delay any
decision to utilise the LDF.
It should be noted that all outstanding UK tax liabilities are eligible to be declared via the LDF, and
will attract the benefits of the LDF, not just those in relation to the relevant property in Liechtenstein.
This effectively means that all undeclared assets, income or gains worldwide can be regularised
on the same extremely favourable terms.
We are not in a position to advise you and/or the Persons with an Interest about the total charge that is
likely to be applied by utilising the LDF. However, experience to date suggests that an average total
5? The "naming and shaming’ policy was implemented by section 94 of the Finance Act 2009 with effect from 1 April 2010
and applies to all cases of deliberate tax default of £25,000 or more
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