The Liechtenstein Government and HM Revenue and Customs have recently issued a second joint declaration in relation to the Liechtenstein Disclosure Facility (LDF).
In order to qualify for the terms of the LDF, it is not necessary for assets to have been held in Liechtenstein historically. Instead a taxpayer could invest in relevant Liechtenstein property now so as to be able to utilise the favourable terms of the LDF for undisclosed UK tax liabilities in past years.
The original memorandum of understanding merely noted that relevant property must be part of a meaningful relationship, however the second joint declaration expands on this to say that any new relevant property must not only be meaningful but also of sufficient value and permanence to reflect the spirit of the LDF.
It is unclear at this point as to what level of investment is likely to be considered as ‘sufficient value’, however further clarification is to be provided by HM Revenue and Customs in due course.