LDF and MDF – Summary of Terms

With the number of voluntary disclosure facilities made available by HMRC, either now or previously, choosing the right one for you or your client can be difficult.  Both the LDF and MDF are now finished but the following gives a flavour of how they operated.

As with all tax problems, circumstances vary greatly and not all of the terms and conditions of the Manx Disclosure Facility (MDF) or Liechtenstein Disclosure Facility (LDF) will apply in all cases.

Although helpful, it is not as simple as just looking at HMRC’s detailed guidance: there may also be other voluntary disclosure facilities to consider, particularly as HMRC task forces target different trades and vocations.

To be sure of which will apply to you, seek specialist advice from the inTAX experts now

The following table gives a broad idea of the differences and similarities between the Liechtenstein Disclosure Facility (LDF) and the Manx Disclosure Facility (MDF).

Term MDF LDF
Eligibility
Offshore asset on 31 December 2013 1 September 2009
Previous tax investigation X
Exception Any previous investigation No current CDF case, and no current criminal prosecution
Benefits
Immunity from Prosecution X
Applies to years 1999 1999
Penalties
Up to 2008/09 10% 10%
2009/10 20% 20%
Post 2009/10 Up to 40% per appropriate regime
Composite rate option? X
Timing of payment? On application to register At the time of disclosure – After acceptance into the LDF
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