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September 19, 2013

Testimonial - Disclosure to HMRC under the Liechtenstein Disclosure Facility (LDF)

Testimonial from Mr AT

 “Dear Paul

I write in response to your request for feedback.

The review that you initially provided of my situation allowed me to understand that it was probably going to be better to make a disclosure under the Liechtenstein Disclosure Facility (LDF) rather than suffer the UK-Swiss Tax Treaty one off levy.  This certainly proved to be the case.

Your thorough and robust approach to the calculations and their presentation allowed me to make my disclosure in a confident manner and I was very pleased that HMRC did not enquire into the disclosure.

In general, I was delighted with the service and results delivered by Vikki and yourself.

Mr AT”

The Work

 -          Advice comparing the Swiss Tax Treaty with the Liechtenstein Disclosure Facility (LDF) and/or voluntary disclosure to HMRC,

-          Illustrative comparative calculations of the tax, interest and penalties at stake so as aid in the decision making process,

-          Detailed calculations of UK tax liabilities using information from overseas bank account statements,

-          Review of historic tax returns to identify any potential underpayments to be disclosed to HMRC,

-          Detailed analysis of tax treatment of offshore funds,

-          Disclosure to HMRC under the LDF,

The Result

 -          HMRC accepted LDF disclosure and calculations of tax, interest and penalties without amendment

-          Tax saving of over £166,000 compared to the one off levy under the UK-Swiss Tax Treaty which would have been payable in May 2013 had no action been taken

Specific benefits of making the disclosure through the LDF include:-

  • Reduced rate of penalties as compared to a voluntary disclosure or unprompted HMRC enquiry/investigation
  • Guarantee of no criminal prosecution
  • Past tax liabilities brought up to date giving relief to the client and preventing an enquiry by HMRC

Note - Testimonial received 16 September 2013


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