10 things you need to know about the Liechtenstein disclosure facility (LDF)

1. An agreement signed between the UK and Liechtenstein Governments requires ‘financial intermediaries’ in Liechtenstein to be satisfied that their UK customers have been declaring their Liechtenstein investments to HMRC.
2. Disclosures under the LDF can be made between 1 September 2009 and 31 March 2015. 
3. A disclosure under the LDF may be required if;
   
   
   • you are contacted by your financial intermediary in Liechtenstein, or
   • you believe you have unpaid tax liabilities arising from assets held in Liechtenstein.
     
     
4. You will be required to prove to your financial intermediary that;
   
   
   • you do not have to pay tax in the UK, or
   • your UK tax affairs are in order, or
   • you have made a disclosure under the LDF.
     
     
5. When notifying your intention to disclose you will be provided with a registration certificate by HMRC. 
6. Disclosures will normally carry a fixed 10% penalty (or no penalty where an innocent error has been made). The disclosure may have to cover several years, up to a maximum of 10 years.
7. Your disclosure must be made within seven months (if using the single composite rate of tax) or 10 months (if you are calculating your liability on an actual basis) of the registration certificate date. HMRC will review every disclosure made under the LDF.
8. People found to have tax liabilities relating to Liechtenstein assets/accounts and who don’t come forward can expect penalties of up to 100% and run the risk of criminal prosecution.
9. If you have accounts or assets outside of Liechtenstein you may, in certain circumstances, be able to transfer these assets to Liechtenstein and take advantage of the terms of the LDF.
10. PwC have a team of specialists who will be able to help you through this process quickly and cost effectively.