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What you need to know about the new LDF rules

Taxpayers who have reported tax avoidance schemes under the DOTAS rules or been subject to an HMRC enquiry for more than three months will be unable to take advantage of the Liechtenstein Disclosure Facility (LDF) following the latest UK/Liechtenstein joint disclosure. The change is intended to block abuse of the LDF by employers using employee benefit trusts (EBTs) and coincides with HMRC’s decision to close its preferential ‘settlement opportunity’ for EBTs in March 2015.

What is the background to the proposed changes?

Gary Ashford (GA): HMRC issued new guidance in relation to the Liechtenstein Disclosure Facility (LDF) on 14 August 2014 with the changes coming in with immediate effect. A new Fourth Joint Declaration was also released.

One of the main reasons for the changes came out of a review that HMRC had undertaken in relation to the fact that in 2013 a number of cases...

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