Liechtenstein Disclosure Facility
Liechtenstein Disclosure Facility

The following Private Client guidance note provides comprehensive and up to date legal information covering:

  • Liechtenstein Disclosure Facility
  • LDF—legal basis and context
  • Who is eligible to participate in the LDF?
  • Benefits of disclosure under the LDF
  • Time limits for the LDF
  • Tax, interest and penalties under the LDF

The Liechtenstein Disclosure Facility (LDF) was a voluntary disclosure facility that extended to all main taxes including, but not limited to, income tax, corporation tax, PAYE, capital gains tax, VAT and inheritance tax. The LDF opened in September 2009 and was originally scheduled to run until 2015. It was then extended to 5 April 2016 before the closure was brought forward to 31 December 2015.

The LDF was available to all UK taxpayers, including individuals, executors, trustees, partnerships and companies. It was targeted at those with UK tax liabilities connected to Liechtenstein, although taxpayers with no existing connection to Liechtenstein could bring themselves within the scope of the LDF by, for example, opening a bank account in the jurisdiction. It allowed for the disclosure of tax irregularities relating to a period of ten years prior to April 2009 and for settlement on beneficial terms, with a guarantee of no prosecution, except in exceptional circumstances.

The remainder of this Practice Note provides a summary of the terms of the LDF.

For more guidance on the LDF, see Clarke's Offshore Tax Planning 2015-16 (22nd edition), Chapter 102 and the further reading link to Simon's Taxes in the related documents pod. See also HMRC's detailed guidance: Offshore disclosure facilities: Liechtenstein.

LDF—legal basis and context

In August 2009, the governments of Liechtenstein and the UK signed a