Volltext: The future importance of tax compliant clients

LDF and Swiss-UK Tax Agreement 
has a single contact person, which ensures consistency throughout the process." HMRC aims to fulfil 
their obligations within 6 months.” 
The “bespoke service” is a major advantage of LDF and allows critical LDF cases to be discussed in 
advance. In addition, the assurance that every LDF case has a single contact person is unusual in a 
huge organisation such as HMRC. HMRC has been satisfied with the implementation of their bespoke 
service since an analogous service will be implemented in the coming disclosure facility with the Isle 
of Man.” 
2.3.4 First Joint Declaration 
The First Joint Declaration was signed on the same date as the MoU and the TIEA. In contrast to the 
MoU, joint declarations are not legally binding under international law. Instead, they are a declaration 
of intent with further information and clarification for the MoU. 
The Joint Declaration stated that a double tax treaty would be signed within the next 12 months. The 
declaration ensures that HMRC will not make criminal investigations against Liechtenstein FIs for 
past actions, provided the LDF is a success and no more relevant persons have undisclosed assets in 
Liechtenstein and no criminal investigations (tax related) are taken against relevant persons.“ 
The Government of Liechtenstein and HMRC want to provide written guidance regarding recognition, 
characterisation and treatment of fiduciary relationships and entities in Liechtenstein. The written 
guidance for trust enterprise and establishments was to be agreed within 3 months (appendix A and B 
of Joint Declaration).* 
The Joint Declaration explains possible approaches for when a relevant person does not cooperate with 
the FI. The FI has to cease providing relevant services. HMRC and Liechtenstein want to create fur- 
ther avenues such as fines on the relevant properties or deduction or retention taxes. The parties have 
?! Memorandum of Understanding, 2009, schedule 6, no. 13, sec. b. 
?? Memorandum of Understanding, 2009, schedule 6, no. 13, sec. d. 
?3 Memorandum of Understanding between the Government of the Isle of Man and Her Majesty 's Revenue and 
Customs of the United Kingdom of Great Britain and Northern Ireland relating to cooperation in tax matters. 
?* Hosp & Langer, 2011 (3), p. 239. 
%5 First Joint Declaration, 2009, p. 1&2. 
?'$ First Joint Declaration, 2009, p. 2&3. 


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