The UK/Liechtenstein TIEA signed on 11 August 2009 entered into force on 2 December 2010.

As many readers will be aware, the agreement also includes a five-year special disclosure facility in the UK and, in Liechtenstein, a five-year taxpayer assistance and compliance programme. More information on the special disclosure facility from HMRC can be found at http://www.hmrc.gov.uk/disclosure/liechtenstein-disclosure.htm

The agreement seeks to regulate the exchange of tax information, to facilitate tax cooperation and taxpayer assistance, in addition to assisting the maintenance and development of Liechtenstein's financial services industry.

The agreement also confirm the overall intention of both parties that by the conclusion of the five year period contemplated, there will be no beneficial owners who are liable to taxation within the jurisdiction of either the UK or Liechtenstein who are ‘using the laws of the other to disguise such liability without paying appropriate tax in the manner contemplated by the understanding’.

The full text of the agreement can be found at http://www.hmrc.gov.uk/international/liechtenstein-eol.pdf