In 2009 HMRC announced the Liechtenstein Disclosure Facility (LDF) that allows holders of offshore accounts to come forward and make a disclosure on potentially favourable terms. This facility is still available and while there are some limitations on the origins of accounts it remains a relatively straightforward and cost-effective way to come clean.

The LDF has the following features:

• Immunity from prosecution.
• Fixed penalty of 10% of evaded tax.
• All tax liabilities (including inheritance tax) incurred prior to 5 April 1999 are ignored.
• The option for a composite rate tax (levied on income at 40%).

To qualify for the LDF taxpayers must have underpaid tax and have held an overseas asset that gave rise to at least some part of the understatement as at 1 August 2009. They must also have made a suitable investment in Liechtenstein prior to the making of a disclosure. Thus it is possible, even now, to qualify for the facility by making an investment in Liechtenstein now.

We have a team of tax investigation specialists who have already helped many clients to make disclosures using the facility. If you would like to discuss your circumstances in complete confidentiality then please call us now on 0800 032 8374. If relevant we can also contrast the LDF with the recently announced agreement with the Swiss authorities.