LDF and Swiss-UK Tax Agreement
2.5.4 Liechtenstein and the United Kingdom
HMRC and the Liechtenstein government are more than satisfied with the success of the agreement, as
shown by the increased number of participants and the extension of the disclosure period until 2016.
At the beginning of 2013, there had been 3,910 registrations for the LDF, which has yielded GBP
455m.” In comparison, the New Disclosure Facility offered by HMRC in 2009 had more than 50,000
disclosures but only yielded around GBP 700m.’ A person involved in the LDF working group of the
trustees association believes that most of those already registered had their main offshore accounts in
Switzerland and used the LDF to anticipate the Swiss-UK tax agreement. The real range of coverage
can only be assessed once the final response deadline for FIs’ existing clients has passed. This will
happen on 30 September 2013.
For some individuals, the disclosure and hence revelation of their name to HMRC may be uncomfort-
able or unsatisfactory. In my estimation, the concept of tax evasion is vanishing and, sooner or later,
an automatic tax information exchange will be agreed in all European countries. The LDF is a good
opportunity; playing hide and seek with assets is doomed to fail in the increasingly digitally connected
world. Unlike legal tax avoidance, tax evasion is no longer an opportunity for clients and financial
service providers.
3 Comparison with the Swiss-UK Tax Agreement
3.1 The Agreement
The agreement, together with the Switzerland/Austria agreement, is the first to handle the problem of
untaxed assets in Swiss bank accounts and deposits. Previously, Switzerland strongly relied on its
banking secrecy to protect bank clients’ privacy and only granted judicial assistance to states when
strict specifications were met.*** The agreement consists of two essential provisions. The first is a ret-
rospective taxation of bankable assets of UK individuals after a one-off deduction and the second is a
withholding tax for subsequent earnings and gains of the same assets.” Individuals also have the op-
tion to make a voluntary disclosure.” This applies to UK-based individuals with a UK address and a
bank account with a Swiss paying agent on the December 31, 2010, and January 1, 2013. The person
2 HMRC, 2013 (7).
?? Watt, 2013, p. 14.
?^ Moll, 2012, n/a.
795 Urtz, 2012, p. 60 & 61.
9$ Raschauer, 2012, p.145.
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