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Implications of the new changes to the Liechtenstein disclosure facility

KEY POINTS

  • Far-reaching changes to Liechtenstein disclosure facility rules restrict who will receive the “full favourable terms”.
  • Users of marketed avoidance schemes that have a DOTAS reference will be unable to use the LDF.
  • Restrictions where the issue being disclosed is subject to an intervention that is more than three months old.
  • The new rules apply to cases registered after 14 August 2014.

The Liechtenstein disclosure facility (LDF) was announced in August 2009. It allowed taxpayers who met the entry criteria to sort out their tax affairs on in most circumstances preferential terms compared to the normal rules.

The process was aimed at taxpayers with offshore disclosures in particular those with bank accounts or structures in the principality of Liechtenstein. More than 5 800 taxpayers have registered for the LDF and...

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