LDF and Swiss-UK Tax Agreement 
2.3 Legal Framework 
2.3.1 Legislative Basis 
The legislative basis of the LDF is a Memorandum of Understanding (MoU), and three Joint Declara- 
tions.'*' A MoU is a bilateral or multilateral agreement. It is a declaration of intent and demonstrates a 
convergence of will between the parties. In international law, MoUs fall under the category of treaties 
and have to be registered in the UN treaty database.'? Because the LDF was designed and negotiated 
over a short period, the contracting partners were unable to handle every issue. Therefore, HMRC 
provides regularly updated answers to frequently asked questions (FAQs), which also form part of the 
LDF." 
2.3.2 Timeline 
The following timeline gives an insight into the development of the LDF agreement: ^ 
1 April 2009: Start of negotiation 
11 August 2009: Signing of the Memorandum of Understanding and First Joint Declara- 
tion 
31 August 2010: Signing of the UK TIEA Ordinance 
10 November 2010: Signing of the Second Joint Declaration 
22 December 2011: Discussion with different financial intermediary associations with modi- 
fication and clarification of the agreement. 
7. February 2012: Extension of the LDF 
11 June 2012: Signing of double tax treaty and Third Joint Declaration 
11 June 2012: Further clarification of the LDF and amendment of the UK TIEA Ordi- 
nance 
21 November 2012: Appointment of a review panel 
19 December 2012: Double tax treaty entered force 
2.3.3 Memorandum of Understanding 
2.3.3.1 Preamble 
The MoU’s preamble decrees that Liechtenstein introduce a five-year Taxpayer Assistance and Com- 
pliance Programme (TACP), under which financial intermediaries (FI) have to identify persons who 
  
7! Ministerium für Prüsidiales und Finanzen, 2012. 
1# United Nations, 2012 p. 40 & 78. 
^5 HMRC, LDF FAQ, March 2013, sec. 1.1, 1.2 & 1.10. 
7 Ministerium für Prüsidiales und Finanzen, 2012. 
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