LDF and Swiss-UK Tax Agreement
opaque banking system and tax evasion“, namely, prohibition of numbered accounts, “Know Your
Customer” requirements, exchange of information for criminal investigations and voluntary disclo-
sure opportunities.”
Also in 2000, the Financial Action Task Force published a list of states which failed to meet the pro-
visions on international efforts against money laundering and tax evasion.” In 2005, the EU member
states introduced the European Savings Directive to tax interests received by EU-resident individu-
als.” In 2006 and 2007 respectively, Germany and the US used a stolen data CD from LGT to start
investigations to identify and prosecute tax evaders.” Several other data CDs from banks and trustees
in Liechtenstein? and Switzerland? were subsequently obtained.
In 2012, at the G20 summit, the leaders published a joint declaration of their intention to extend the
European Savings Directive by including dividends, capital gains and royalties and to close loopholes
by including a rule for companies, trusts and investments funds. However, implementation is still
blocked by Austria and Luxembourg, who claim such an extended automatic exchange of tax infor-
mation would undermine their banking secrecy.”
1.3 Role of Liechtenstein in the Developments
1.3.1 Initial Situation
For a long time, Liechtenstein had the reputation of being a “Mecca” for unreported money. This was
due to banking secrecy, strong professional confidentiality and the refusal of mutual administrative
and legal assistance in tax matters.? Furthermore, the establishment of discretionary foundations and
establishments with moveable founder's rights and thus the concealment of the founder and the bene-
ficiaries was a keystone that enabled advisors to hide their clients’ untaxed assets.” Ordower, states
* Hosp & Langer, 2012 (2), p. 348.
? Watt, 2012, p. n/a.
^? FATF, 2012.
7 Watt, 2012, p. n/a.
? Financial Times Deutschland, 2008.
? Pfohl, 2008.
? Samson & Wulf, 2012, p. 245.
?! Dalton, 2012, p. n/a.
? Vogel & Ashauer-Moll, 2010, p. 93.
3 Carlé, 2008, p. 125 & 126.
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