Volltext: The future importance of tax compliant clients

LDF and Swiss-UK Tax Agreement 
[3] Alternatively, if you, or the Person(s) with a Beneficial Interest, believe that there may be 
outstanding UK tax liabilities, you or they may wish to take advantage of the special terms of the 
LDF in order to regularise the position. Please note that the LDF can also be used in the event of un- 
certainty about any UK tax liability. Once the LDF has been utilised, HMRC will issue a formal regis- 
tration certificate as well as a disclosure certificate which you, or the Person(s) with a Beneficial 
Interest, will then need to provide to us as evidence that the outstanding tax liabilities have been regu- 
For your convenience, we have summarised the key provisions of the MoU and the LDF in the en- 
closed Fact Sheet. Further details about the special terms of the LDF are set out later in this letter. 
It is important that we receive sufficient evidence to satisfy us in relation to one of the three options 
described above ([1], [2] or [3]) within 18 months of the date of this letter, as summarised in the 
enclosed "Checklist regarding Tax Liability and Compliance". 
Under Liechtenstein law, if one of these options is not satisfied within that 18 month period, the Fi- 
nancial Intermediary may have to cease to provide services to you. This may prevent you from dealing 
with the Relevant Property or receiving payments or distributions; it may also prevent the Financial 
Intermediary from continuing to invest or administer the Relevant Property. It is therefore important 
that you read this letter and the various enclosures in order to determine what you or the Persons with 
a Beneficial Interest need to do next. 
Even though you, or the Persons with a Beneficial Interest, have 18 months to provide us with the 
information referred to in paragraphs [1], [2] or [3] above, we would be grateful to receive a response 
as soon as possible (and in any event well before this deadline) in order to allow any issues or queries 
to be resolved in good time. 
Please note that if you do not have any beneficial interest in relation to the Relevant Property, it is 
important that you immediately forward this letter and all enclosures to the Persons with a Beneficial 
Interest so that they can take the appropriate action referred to above within 18 months of the date of 
this letter. 
What is the LDE? 
The LDF is a unique voluntary disclosure programme operated by HMRC in the UK that allows UK 
taxpayers to regularise previously undisclosed tax liabilities on extremely favourable terms. It has 


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