Volltext: The future importance of tax compliant clients

LDF and Swiss-UK Tax Agreement 
255 or the 
With the exception of any taxes withheld under the European Union Savings Directive 
equivalent agreement between the European Union and Liechtenstein, no tax deduction, relief or al- 
lowance is possible for the past or the future under the CRO.?'^ The CRO has to be selected for the 
whole period (1999 until 2009) or not at all.?" Losses cannot be carried forward under the CRO. Only 
losses within a given year can be aggregated ?'* 
The relevant period from 1999 to the year of application was a strong benefit in the first years of the 
LDF due to the huge difference from the normal 20 year lookback period. Nowadays, this benefit is 
reduced, since the relevant period is still from 1999 until today. A rolling 10 year lookback period 
would be more advantageous for the LDF but is not negotiable. 
The CRO is a simple and efficient opportunity for calculating the tax rate of eligible persons. This 
opportunity saves time and reduces advisors' fees. Therefore, it is incomprehensible that HMRC does 
not offer a CRO for the tax year 2009/2010. The fixed starting point and the missing CRO for 
2009/2010 may be rightly seen as a disadvantage for the LDF. Hosp identified the CRO as one of the 
most important elements of the LDF, due to its simplicity and because all taxes, as well as national 
insurance contributions, inheritance tax, stamp duty, corporate income tax, personal income tax and 
capital gains, are covered.?? Punishment 
Penalties are reduced to 1095"? before 2009 and 2096?" after 2009 and the persons are assured against 
criminal investigations. A person under investigation by HMRC or already contacted is not an eligible 
person. ^? The term “under investigation” applies to individuals who have received notification from 
HMRC, which declares that their tax affairs are under investigation under the regulation of the Code 
of Practice 9, which covers cases of suspected fraud.” An individual is formally notified if the indi- 
vidual or his advisor receives a notification by post, by hand or by telephone. Individuals who were 
13 Council Directive 2003/48/EC 
218 HMRC, LDF FAQ, March 2013, sec. 7.3. 
27 HMRC, LDF FAQ, March 2013, sec. 7.6. 
28 HMRC, LDF FAQ, March 2013, sec. 7.12. 
2? Hosp, 2009 (1), p. 723. 
?? Memorandum of Understanding, 2009, schedule 6, no. 1, sec. e. 
?! HMRC, LDF FAQ, March 2013, sec. 6.2. 
?? Memorandum of Understanding, 2009, schedule 6, no. 3. 
?3 Berwick, 2010, p. 45. 
?^ HMRC, LDF FAQ, March 2013, sec. 1.23. 


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