The deadline for registering an intention to disclose unpaid tax
under the New Disclosure Opportunity (NDO) passed on 4 January.
However, people can still come forward using the Liechtenstein
Disclosure Facility (LDF). Adrienne Kerry of PKF Accountants &
business advisers in Birmingham, suggests it could be significantly
cheaper to come forward now under the LDF.
Adrienne said: "Individuals registered to use the NDO will have
to come clean about un-declared income over the last 20 years.
However, if the LDF route is used it is a much shorter period of
around 10 years. Because the difference in the number of years
involved is so stark, the tax - and interest - saved can be
significant.
"Unlike the NDO it is still possible to register for the LDF. If
you have already registered for the NDO it is possible to transfer
to the LDF."
For example, consider the position where an individual had
£1m of clean funds deposited overseas at the start of the tax
year 1990/91 and it earned interest at a steady 5%. The tax and
interest and penalty charges owed to HMRC under the NDO would be
around £967,000. The equivalent under the LDF would be just
£493,000, a massive difference of £473,000. The savings
may be even more marked if the original capital in the account has
not been taxed or inheritance tax is outstanding.
Adrienne continues: "Clearly there is a tax saving, but a major
reason for the difference is the interest on the overdue tax which
adds up very quickly indeed. In the early 1990s this was charged at
well over 10% for a number of years and, under the NDO
calculations, totals more than 100% of the actual tax due for the
first few years.
"It is an absolute myth that you must already have a
Liechtenstein bank account in order to benefit from the LDF. An
interest in relevant property in Liechtenstein can be acquired now
and the benefits of the LDF obtained. There are, of course, other
variables to properly consider for each individual before
determining whether the LDF is viable but, in the right
circumstances, the potential savings are significant."