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Unfair disparity between Liechtenstein tax deal and the New Disclosure Opportunity


11 August 2009: PKF Accountants & business advisers welcomes the new tax amnesty announced today between HM Revenue & Customs (HMRC) and the Liechtenstein authorities, but says the difference in terms to the New Disclosure Opportunity (NDO), are unfair.

The Liechtenstein tax deal offers account holders the opportunity to settle any unpaid tax with only a 10% penalty and going back only as far as 10 years. In contrast, the NDO set to begin in September this year, is asking UK taxpayers with investments in other offshore jurisdictions to declare unpaid tax as far back as 20 years. In some cases they may also have to pay a 20% rather than a 10% penalty.

John CassidyJohn Cassidy, Tax Investigations partner at PKF said, “It is wholly unfair that there are different rules for those with investments in Liechtenstein and those with investments in other offshore jurisdictions.

“The rights or wrongs of how the original data for Liechtenstein was obtained are one thing, but to make it clear that the data was not even used, by offering an amnesty, takes the situation to another level. The disparity of terms between the new amnesty and the NDO is the final nail in the coffin.”

John continued, “For those with investments in Liechtenstein there is no doubt that this is a great opportunity to declare any undeclared income or gains and square matters away with HMRC once and for all so I would urge people to make use of the facility. But I also urge HMRC to align the terms of the NDO with this new amnesty.

“Anecdotal evidence suggests that the 20 year time limit had a hugely negative impact on the overall amount of tax that HMRC collected for the previous amnesty, the Offshore Disclosure Opportunity (ODF) in 2007, as many were put off by the sheer enormity of the project; 20 years was simply seen by many as too daunting. Today’s news only provides a further disincentive for those supposed to use the NDO simply because they banked in a different place.”

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For further information, please contact:

Jane Murray, PR, 020 7065 0135, jane.murray@uk.pkf.com

Notes to Editors:
  1. PKF is a leading firm of accountants and business advisers with more than 1,500 partners and staff operating in 23 offices in the UK mainland firm, a wholly-owned financial planning company and associated offshore practices. The firm specialises in advising growing and entrepreneurial/owner-managed businesses, AIM and fully listed companies, and also has extensive experience in the public and not-for-profit sectors. Principal services include assurance and advisory; taxation; consultancy; corporate recovery and insolvency; corporate finance and forensic. The firm has particular expertise in advising sectors such as hotels and leisure; mining and resource; public sector; real estate and construction; professional practices; not-for-profit; and medical. The firm’s web site is www.pkf.co.uk.
  2. PKF (UK) LLP also offers financial services through its FSA authorised company, PKF Financial Planning Limited. PKF (Isle of Man) LLC is a limited liability company registered in the Isle of Man. PKF (Guernsey) Limited is incorporated in Guernsey.
  3. PKF (UK) LLP is a member firm of the PKF International Limited network of legally independent firms. The PKF International Limited network has more than 14,650 people operating in 119 countries around the world.


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