Tax payers using the Liechtenstein Disclosure Facility (LDF) must give “informed consent” to their tax investigations specialists to communicate with HM Revenue & Customs via e-mail due to concerns over security.

While a form 64-8 gives HM Revenue & Customs authority to communicate with a person’s appointed representative, it fails to cover the forms that such communicates should take. It is generally accepted that it covers just letters and phone calls, but fears persist over the possibility that these forms of communication are vulnerable to interception, letters can be read and alterations made without either the senders or the recipients knowledge.

As a result, HM Revenue & Customs has sent letters to tax investigations specialists advising that for all new registrations, communication via email will “only happen if [the] client has given their informed consent”. HMRC will also provide an accompanying form that can be used for that purpose.

HM Revenue & Customs said it hopes no additional inconveniences are created following the decision.

The move however, will not affect clients already seeing their cases addressed via e-mail.

The controversial LDF scheme enables Britons to obtain a generous settlement with HM Revenue & Customs on any undisclosed tax liabilities held in offshore bank accounts, by rerouting funds through the European principality. Originally due to end in March 2015, strong demand for the scheme saw it extended until 5 April 2016. HMRC announced restrictions to the service in August 2015, which will see access to the most generous terms on offer reduced.