How far back does an LDF participant need to pay any unpaid UK liabilities?
Where deliberate behaviours are demonstrated, payment of UK tax liabilities under the LDF go back: • To April 1999 where favourable LDF terms apply • 20 full tax years back from the beginning of the tax year in which the full disclosure is made for unpaid taxes in relation to a bank account (including a financial (portfolio) account) outside the UK or Liechtenstein which is in the UK taxpayer’s name at 11 August 2009 and was opened through a UK branch or agency of that bank. • 20 full tax years from the beginning of the tax year in which the full disclosure is made for unpaid taxes relates where the UK taxpayer did not hold an offshore account or asset at 1 September 2009. Where exceptionally, behaviours are not considered deliberate the following time limits will apply: • Where reasonable care is demonstrated and an incorrect tax return has been submitted, four full tax years (from the end of the tax year in which the disclosure is made). • Where there has been a failure to notify and
