A Liechtenstein Trust is set up by a deed between the settlor and trustees. The trust deed does not have to name the beneficiaries. If the trust deed is deposited with the Liechtenstein Registrar of Trusts, it will not be publicly available, and later instruments, which might, for example, name beneficiaries, who might just happen to be Anglo Saxon, do not have to be disclosed. So if the trust is established with Liechtenstein trustees, there is no reason why the details of UK resident beneficiaries should show up in an audit.
For once I'm going to argue against the case presented here: know your client rules should disclose the UK link.
If they don't we have a much bigger problem with Liechtenstein.
Of course that is possible: the new deal is predicated on there being real reform in Liechtenstein. If it really is a sham then the gains will be limited, money will leave without anti-money laundering suspiscious transaction reports beingn filed and cash recovery will be low.
But having toured the BBC yesterday talking about this issue I'll confirm just exactly what I think: underlying this agreement is a weak Tax Information Exchange Agreement. Laid on top of it is the evidence that no one has confidence in Tax Information Exchange Agreements: the Proactiave Information Exchange Agreement as I have called it.
The PIE may not work. But sometimes you just have to try, and it's better than just having a TIEA. Which is why I was trumpeting this as good news.
But I'll be quite candid: I can be proved wrong.