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New Disclosure Opportunity (NDO)

Liechtenstein Disclosure Facility (LDF)
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The New Disclosure Opportunity (‘NDO’)

Latest News

  • Deadline for registration expired on 4 January 2010
  • Disclosures must be filed and tax paid by 12 March 2010
  • Banks  have started to provide information to HMRC
  • HMRC state that taxpayers who did not come forward under NDO may face penalties of up to 100% of the tax owed and some may face prosecution
  • Moving funds to Liechtenstein may offer a chance to extend the time limit for disclosure for clients who did not register by 4 January, to escape prosecution, and also to legitimately limit the tax payable in cases where tax arrears go back to before 6 April 1999. 

This is a highly complex issue and you must take specialist advice before taking action.

The New Disclosure Opportunity (‘NDO’) was announced on 1 September 2009.  In a nutshell, anybody with unpaid tax liabilities that are in any way connected with an offshore asset can come forward and settle on advantageous terms. But you must have registered with HMRC by 4 January 2010 or the chance is lost. Having registered with HMRC, you must submit the standard disclosure forms and pay the settlement by 12 March 2010.

If you are reading this web page now, you probably fall into one of the following two categories.  Click the relevant one for more information:

Practical advice for clients and professional advisors

The purpose of these notes is to offer some practical advice and tips based on our years of experience in handling offshore tax investigations. We have extensive experience in handling offshore disclosures of all types, including the 2007 Offshore Disclosure Facility, where all of our disclosures were accepted by HMRC without any further questions. We assist professional advisors and clients direct.  Just follow the appropriate link below.

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On 7 January 2010 HMRC issued the following statement:
"Now the NDO is closed, HMRC is beginning the job of using the data we have obtained from banks to identify people who have not made disclosures despite having hidden their money offshore. We are starting our investigations and penalties can be up to 100% of the tax not paid. But it's very important to remember that, when someone comes forward voluntarily, the penalty is always lower than when we catch the evader. This means it's still well worth contacting HMRC if you have undisclosed offshore accounts."