HMRC Attack Offshore – Liechtenstein LDF

HMRC Specialist Investigations Office is maintaining a sustained attack on UK taxpayers holding offshore accounts. Offshore account holders are especially at risk as HMRC continue to review banking material obtained via means such as Memoranda of Understanding with offshore centres.

There is a unique proactive solution to regularise all your tax affairs which is available to those whom have an account in Liechtenstein. Under the Liechtenstein Disclosure Facility (LDF)  self-disclosure of tax irregularities arrangement all tax liabilities connected with offshore bank accounts and structures held anywhere in the world may be settled on favourable terms.

Essenitally provided a Liechtenstein connection is established the LDF can be used as an umbrella for the disclosure of any tax liability connected with an overseas asset. Overseas assets do not need to be transferred to Liechtenstein to qualify.

The benefits of the LDF special arrangement:

• A guaranteed immunity from prosecution for tax related offences;
• Ability to have initial “no names” discussions with HMRC, prior to making a disclosure;
• Tax liability limited to 10 years as opposed to the normal 20 year rule;
• There is no time limitation for the recovery of undisclosed Inheritance Tax liabilities. Under the LDF, Inheritance Tax will also be limited to 10 years, which is a significant concession in relation to inherited wealth;
• A simplified composite rate of tax (the CRO) which, if used in the right circumstances, can reduce liabilities even further;
• There is no ‘name and shaming’;
• There is an efficient disclosure process with no obligation to meet HMRC; and
• The LDF is likely to run until 31 March 2015.