Guidance

Offshore disclosure facilities: Liechtenstein Disclosure Facility

How you could register and make a disclosure if you hold investments in Liechtenstein. The facility closed on 31 December 2015.

Overview

The Liechtenstein Disclosure Facility (LDF) gives eligible UK taxpayers the chance to declare their worldwide income and bring their UK tax affairs up to date quickly and without having to undergo an in depth investigation.

You can use these facilities to make a full disclosure of outstanding liabilities and pay any amount you owe. To qualify you need to :

  • have owned an offshore asset on 1 September 2009
  • hold investments in Liechtenstein at the time you register for the LDF
  • have registered by 31 December 2015

If you’ve registered for the LDF you must make a disclosure of all outstanding liabilities for the period from 1999 and pay the resulting liabilities. In return:

  • you’ll not be prosecuted if you make a full disclosure
  • the penalty you pay will normally be limited to 10% for all years before 2009
  • you’ll not have to pay any tax due for years before 1999
  • you’ll have an option to pay the tax you owe using a single rate of tax to cover all income
  • you’ll receive a bespoke service ensuring matters are dealt with as quickly as possible

What you should do next

To make a disclosure:

  1. establish that you have a tax liability.
  2. confirm you qualify (ensure your circumstances meet the conditions for using this facility)
  3. apply to H M Revenue and Customs (HMRC) to register to be able to make a disclosure - by 31 December 2015
  4. make your disclosure and return your pack to HMRC as soon as possible.

Most people who register for the LDF engage an advisor to help them and you should consider doing this.

Establish tax liability

If you’re not sure you owe tax you can get help.

Confirm that you qualify

The full eligibility criteria are set out in the detailed guidance but you must hold an investment in Liechtenstein at the time you register and you must not be ‘under investigation’ by HMRC (see 1.22 in the Disclosure facility detailed guidance).

In some circumstances you’ll be eligible to register for the LDF but will not be eligible for the full favourable terms. These include the circumstances described in section A and at paragraph 6.1 of the Disclosure facility detailed guidance.

If you need help to establish whether you’re eligible you can contact the Offshore Disclosure Facility helpdesk.

You should also check the Disclosure agreement details: memorandum of Understanding within the detailed guidance.

Apply to register

Full details on how to apply to register for the LDF are in the Disclosure Pack.

You can apply to register to use the Disclosure Facility by post, email or fax.

Email: ldfteam.siliverpool@hmrc.gsi.gov.uk

Fax: 0151 933 9958

Make your disclosure

You must normally make your disclosure within 10 months of registering. Full details on what is required are in the Disclosure Pack. Once complete post your documents to HMRC.

Published 12 February 2015
Last updated 1 April 2016 + show all updates
  1. The disclosure facility closed to new applications on 31 December 2015
  2. Disclosure date change.
  3. First published.