Liechtenstein Disclosure Facility is a mechanism that allows those with undisclosed overseas assets to be compliant with HMRC, whilst paying limited penalties and with immunity from criminal charges. In this case study we assisted a non-UK EU national to normalise his tax affairs with HMRC.

Client Challenge

Our client is an EU national and has been resident in the UK for several decades. He moved to the UK to work for a subsidiary of his EU country employer and retired in 1999. He had overseas income and gains for many years which had not been declared to HMRC.

Our client wanted to make an unprompted disclosure to HMRC and bring his tax affairs up-to-date.

How did Bedrock help?

The Bedrock team investigated the options available to our client and found that he could make use of the beneficial terms of the Lichtenstein Disclosure Facility. Our team introduced the client to a financial institution in Liechtenstein and registered him so he could use the Liechtenstein Disclosure Facility. We reviewed the financial information and records provided by the client, produced schedules detailing his income and gains for each year in question and calculated his tax liability after claiming all possible reliefs.

Once our team had calculated the interest and penalty due and advised the client to make a payment on account early in the process. A report was produced to accompany our calculations which fully explained our client’s affairs and the tax treatment of his various sources of income.

Our team then assisted with making the disclosure to HMRC.

Impact and Benefits

Our team were able to make a full disclosure to HMRC on behalf of the client under the Lichtenstein Disclosure Facility within the imposed time-limit. As a result our client was able to repatriate the offshore funds without fear of further challenge by HMRC.

Financial benefits

The amount payable by the client to settle his affairs was significantly less than he had anticipated. The team were able to claim double tax relief and utilise statutory tax reliefs to reduce the liability on some of the client’s more complex investments. Our team identified that under the terms of the Lichtenstein Disclosure Facility income and gains predating the 1999/00 tax year did not require consideration. The 10% penalty payable under the Lichtenstein Disclosure Facility is considerably less than HMRC would have otherwise sought to charge.

Contact our team today for advice on resolving disputes with HMRC regarding unpaid tax.

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