Posted by : John Carrell
| Date posted : 18/09/2010
Your knowledge in tax and company law, and your tenacity on major issues you identified, have considerably improved the agreements with the UK.
Client
Last summer, Farrer & Co was asked to advise the Principality of Liechtenstein on the groundbreaking tax agreements it was proposing to enter into with the UK. This led to John Carrell, our head of tax, joining the Liechtenstein negotiating team, which hammered out the terms of the Memorandum of Understanding and the Liechtenstein Disclosure Facility at meetings with HMRC in Vaduz, Zurich and London.
Under these agreements, Liechtenstein undertook to require UK investors with undeclared bank accounts to close them within five years or come forward to HMRC and pay the tax that was due. In return, the Principality was able to secure for investors very generous terms from HMRC.
These terms are set out in the Liechtenstein Disclosure Facility and are so attractive that those with undeclared accounts in other countries are now moving them to Liechtenstein. The agreements have been widely perceived as a coup for the Principality.
“I would like to express my gratitude for your most valuable contribution in the negotiations with HMRC,” wrote Prinz Nikolaus von Liechtenstein, Liechtenstein’s ambassador to the European Union, in a letter to Farrers partner John Carrell. “You have not only became a dedicated and diplomatic team member, but your knowledge in tax and company law, including Liechtenstein’s holding structures, and your tenacity on major issues you identified, have considerably improved the agreements with the UK.”