LDF and Swiss-UK Tax Agreement 
Since December 2011, HMRC has required a Confirmation of Relevance”* issued by the FI to accept 
an LDF application.” The certificate ensures that relevant property in Liechtenstein exists at the date 
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of registration.”® Variations of the assets in Liechtenstein after the registration are not of relevance for 
HMRC and do not lead to a suspension or withdrawal of the registration.” 
The requirement to establish a meaningful relationship was requested by Fls in Liechtenstein. It is 
very positive that new clients are only required to transfer a portion of their assets to Liechtenstein 
rather than the whole relevant property.” The exact definition enables FIs to establish a long-term 
relationship. However, in the explanatory notes, it is argued that the relationship should last at least 24 
months. A short survey with some banks in Liechtenstein indicates that this proposed minimum period 
is not strongly implemented. The pressure from clients and competitors may be too high. Of course, a 
minimum term length for a banking relationship is difficult to explain to the clients. Nevertheless, the 
implementation of a clearly defined meaningful relationship is positive for the financial centre in 
Liechtenstein. Goekmen, Head of the Management Board at Kaiser Partner Privatbank AG, says that 
total assets for LDF cases in which he was involved increased from approximately GBP 1 million 
before the new regulation to around GBP 3 million today.“ 
2.4 Cases 
2.4.1 About the Cases 
The following three cases illustrate the application of the LDF. Two cases are designed a representa- 
tive cases to represent a wider range of realistic cases whereas the third is a crucial case.’ A crucial 
case is used to show the impact of the framework on cases, which are extraordinary. The intention of 
crucial cases is the idea that if an argument holds under extreme conditions (crucial case) the likeli- 
hood that this argument is true is high. 
The cases provide groundwork which allows for a comparison with the Swiss-UK tax agreement in 
chapter four. Therefore, the cases are constructed in such a way that they are able to be used for both 
  
?$ Annex E 
?' HMRC, LDF FAQ, March 2013, sec. 3.4. 
?$ HMRC, LDF FAQ, March 2013, sec. 3.5. 
79 HMRC, LDF FAQ, March 2013, sec. 3.8. 
00 Roth & Thiede, 2013, p. 619. 
9! Goekmen, 2013, p. 59. 
3? Christians, 2010, p. 351-355. 
38 Christians, 2010, p. 354 & 355. 
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