Volltext: The future importance of tax compliant clients

LDF and Swiss-UK Tax Agreement 
zens with untaxed assets in Liechtenstein.” The LDF is a tax disclosure opportunity for individuals 
with tax liabilities in the UK and with a connection to Liechtenstein.” 
The reason for the deal with Liechtenstein was explained by the Permanent Secretary for taxation at 
HMRC, Dave Hartnett: 
“There are now 51 states with that information [data discs containing banking information and 
accounts from LGT] and so we thought it would be a good opportunity to enter in a formal 
agreement with the Liechtenstein government"? 
Thus the LDF was also forced by HMRC due to their strategy against tax evasion. In 2007, HMRC 
asked UK operating banks and branches for information on overseas accounts, which resulted in a new 
law in August 2009 requiring operating banks to provide information about overseas account holders 
with a UK address. Since Liechtenstein banks do not fall under this law, the LDF was an opportunity 
to obtain the desired information." Further Reforms 
Besides the new tax agreements and disclosure opportunities, Liechtenstein reformed several laws to 
underline the redirection of the financial sector. The foundation law was revised and, among other 
things, increased the responsibilities of the board of foundation and introduced supervision for charita- 
ble foundations.? 
On January 2011, a new tax law came into force with the aim of providing an internationally accepted 
tax system.” The special taxation of domiciliary companies was ended and all entities, including foun- 
dations, have since been subject to ordinary taxation, with the exception of private asset structures.” 
In January 2013, the Liechtenstein and Austrian governments agreed on a tax agreement based on the 
existing agreement between Switzerland and Austria. This agreement also takes into account the spe- 
>! Her Majesty's Revenue and Customs [HMRC], 2012 (7). 
? Memorandum of Understanding between the Government of the Principality of Liechtenstein and Her Majes- 
ty's Revenue and Customs ("HMRC") of the United Kingdom of Great Britain and Northern Ireland relating to 
cooperation in tax matters [Memorandum of Understanding], Schedule 7, 2009. 
3 Grocott, 2009 (2), p. 3. 
* Barry & Airey, 2012, p. 11. 
°° Thôny Treuhand, 2010, p. 2. 
56 Gesetz vom 23. September 2010 über die Landes- und Gemeindesteuern 
?' 'Thóny Treuhand, 2010, p. 3. 


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