LDF and Swiss-UK Tax Agreement 
HMRC is obliging. Relevant persons, who were unable or, for whatever reason, forgot to react proper- 
ly are not strongly fined under this rule. 
2.3.6 Third Joint Declaration 
2.3.6.1 Miscellaneous 
The Third Joint Declaration stated that the double tax treaty has been signed and takes effect from 1 
January 2013. The parties were satisfied with the MoU. In total, 2,500 taxpayers registered and GBP 
363 million had been accounted for. Due to this success, the parties agreed to extend the MoU to 5 
April 2016.29 
The extension of the LDF is a win-win situation for Liechtenstein and HMRC. FIs should gain new 
clients and HMRC should receive more tax earnings. 
HMRC now provides a single chargeable rate of 50% for the 2010/2011 tax year and will provide 
further information in due course. A single charge rate is not available for the year 2009/2010. HMRC 
states that capital losses outside the normal time limits are an issue in certain cases and will provide 
guidance available in the future.” As already stated, the lack of CRO for the 2009/2010 tax year war- 
rants criticism. 
The declaration also specifies the responsibilities of tax compliant persons. Such persons are now 
permitted to submit a “Certification of Tax Compliance” form to the FI. This form is reserved for per- 
sons who are clear about their tax obligations and does not need to be notarised. The parties will dis- 
cuss whether a similar form will be introduced for new UK clients in Liechtenstein for the future.” 
HMRC declared that some individuals applied to use incurred capital losses acquired before 1999. 
They will permit the use of such "newly discovered losses" in calculating the tax liabilities. However, 
this must be discussed on a case-by case basis via the bespoke service. 
  
265 Third Joint Declaration, 2010, p. 1. 
266 Third Joint Declaration, 2010, p. 2. 
267 Third Joint Declaration, 2010, p. 3. 
268 Third Joint Declaration, 2010, p. 2. 
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