• Regularisation of UK tax affairs with respect to the entire assets worldwide
• Look-back period of only ten years as opposed to the 20 years of the normal disclosure programme
• Cherry picking between the two calculations
• Lesser interest and penalty (10% instead of 20%)
• Assurance against criminal tax investigation
• Current individual asset structure can be maintained to a large scale, only a portion of the assets has to be transferred
• Legal certainty
• Bespoke service: helpdesk support with possibility of anonymous contact with HMRC
• Tax already withheld in accordance with the EU directive on the taxation of savings income will be credited
• HMRC will accept reasonable offers for the payment of the tax based on estimated liability
• Exclusion of the UK taxpayer from the “naming and shaming” procedure announced by HMRC in April 2009 (applicable where the deliberately unpaid tax is more than GBP 25'000)
• Peace of mind for a person who participates fully, since his or her tax affairs will be put in order

HMRC announced in a recent Pre-Budget Report publication that it will intensify the pressure on those who use offshore structures to evade tax. This announcement has been timed to coincide with the revised deadline for registrations under the New Disclosure Opportunity of 4 January 2010 and is a clear statement of intent that HMRC will use their full might against non-compliant taxpayers who do not disclose. Taxpayers should take advantage of the extended deadline, using the LDF where they are able to so – or face the risk of much more severe penalties.