Our client had undisclosed income and gains from a Swiss bank account and wanted to bring his tax affairs up to date whilst ensuring that the tax was calculated correctly and penalties minimised.
Our client was also concerned about the impact of the UK-Swiss tax treaty, under which he would have suffered a one levy of over £300,000 unless action was taken prior to 31 May 2013.
We provided advice and illustrative computations comparing the Swiss Tax Treaty with the Liechtenstein Disclosure Facility (LDF) and a voluntary disclosure to HMRC.
Following our clients decision to proceed with the LDF, we prepared detailed calculations of the UK tax liabilities, liaised with advisers in both Switzerland and Liechtenstein, provided a detailed analysis of the more complex areas of the disclosure and finally corresponded the disclosure to HMRC on our clients’ behalf.
HMRC accepted our disclosure and the calculations of tax, interest and penalties without amendment.
We saved our client over £166,000 compared to the charge he would have suffered under the UK-Swiss Tax Treaty.
Specific benefits of making the disclosure through the LDF included:
- Reduced rate of penalties as compared to a voluntary disclosure or unprompted HMRC enquiry/investigation
- Guarantee of no criminal prosecution
- Past tax liabilities brought up to date giving relief to our client and preventing an enquiry by HMRC