Alpine curriculum

KEY POINTS

• The LDF is a generous disclosure opportunity.
• One-off levy payable under the Swiss deal.
• Tax paid under the Swiss deal must be disclosed.
• Guidance on the interaction between the two initiatives.

The Liechtenstein disclosure facility (LDF) and the UK-Switzerland agreement on tax co-operation (the Swiss deal) are each in their own way groundbreaking arrangements. Their significance and main features are summarised in LDF and Swiss deal (both below; click images to enlarge).

Whether or not the LDF or the Swiss deal was more beneficial depended on the taxpayer’s individual circumstances.

The LDF remains the most generous disclosure opportunity offered by HMRC and they have indicated that they are unlikely to offer such a beneficial facility again.

Crucially the LDF offers immunity from prosecution...