Liechtenstein Disclosure Facility (LDF)

What is it?

The UK and Liechtenstein governments signed a Memorandum of Understanding on 11 August 2009 to ensure UK residents with assets in Liechtenstein were tax compliant from a UK tax perspective and provide a disclosure facility to regularise their tax affairs for the past.

The disclosure opportunity is available until 31 December 2015. Click here to visit our LDF countdown page.

Who does it affect?

To benefit for the full terms of the LDF you must have:

  • UK tax liabilities (IT, CGT, IHT and VAT) of which HMRC were previously unaware and were not the subject of any form of enquiry more than 3 months old prior to registering; and
  • Held an offshore asset as at 1 September 2009 with which there is a substantial connection to the UK liabilities to be disclosed (at least 20%).

The LDF is also available to UK residents who did not hold overseas assets at 1 September 2009 with liabilities that HMRC were previously unaware of.  In these circumstances, the benefit is immunity from prosecution; the other beneficial terms are not available.

Important aspects of the LDF are detailed in the flow chart.

How we can help?

We have successfully represented clients with all types of overseas assets to regularise their tax affairs (overseas companies, foundations and trusts) using the LDF, and we are experienced in advising clients and practitioners on the options available to them. We review each case on its merits and we then advise on the most suitable course of action. At Gabelle one size does not necessarily fit all and we pride ourselves on our bespoke service.

For more information on our Tax Investigation services, please phone our TaxDesk on 0845 4900 509 or email


John Hood

Isobel Clift

Davinia Douglass