Worldwide Disclosure Facility

The Worldwide Disclosure Facility (WDF) is designed to encourage individuals and businesses to voluntarily disclose any overseas income or assets that may not have been previously reported to HMRC, and thus, pay any tax owed on those. This facility is part of HMRC’s broader strategy to tackle offshore tax evasion and non-compliance.

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How will HMRC find out if I have not reported my overseas income correctly?

The Common Reporting Standard (CRS), adopted by the UK along with over 100 other countries have signed up to an agreement to automatically share and exchange information that may be relevant to the tax authorities in other jurisdictions.

I have received a nudge letter, what should I do?

If you have received a nudge letter you should not ignore it, even if you are confident that all overseas income and gains have been reported correctly. There can be substantial penalties for failure to declare offshore matters and so it is recommended that you engage a specialist to determine the correct position. If a disclosure is required Resolve Tax can assist in the preparation of this to ensure it is complete and accurate, mitigating penalties and limiting the number of years to disclosure where applicable.

I want to make a disclosure, what do I need to do?

The first stage, regardless of whether the disclosure is voluntary or prompted, is to register your intention to make a disclosure. If you’ve received a nudge letter this should typically be done within 30 days of the date of that letter.

If you have not received a nudge letter but know that you need to make a disclosure, it is important to act quickly to ensure your position of ‘unprompted’ is protected (which attracts lower penalty rates).

Once the disclosure has been registered, HMRC will write out to confirm this and provide a Disclosure Reference Number (DRN). From this date, you will have 90 days to prepare and submit the disclosure, which must include the tax due, as well as interest and penalties.

HMRC expect payment of the liabilities to be made at the same time as the submission. If this is likely to cause difficulties, HMRC should be informed up front, and a request for a payment arrangement agreed.

Why Resolve Tax?

We have years of experience in dealing with the most serious and complex tax investigations and disclosures as , including Code of Practice 9 enquiries.

Resolve Tax is made up of ex-HMRC inspectors, who understand HMRC’s processes in detail. We can easily identify the most effective way to deal with a COP9 enquiry, and know how to navigate through them in the most effective way possible.

How far can HMRC go back?

The number of years that HMRC can go back will depend on a variety of factors, with the maximum being 20 years. This can be reduced depending on behaviour and whether returns have been previously filed with HMRC.

Where there are inaccuracies in returns resulting from non-deliberate behaviour, the time limits for offshore matters were extended from 4 years (reasonable care was taken) and 6 years (careless), to 12 years. This was not retrospectively applied so HMRC cannot yet go back the full 12 years.

Will I be charged a penalty?

HMRC introduced the Requirement To Correct (RTC) in 2017, which gave taxpayers up until 30 September 2018 to disclose all irregularities with their overseas income and gains.

Disclosures made after this date, relating to tax years up to and including 2015/16 will attract the significantly increased penalties under the Failure To Correct (FTC) regime. For a prompted disclosure the penalty rate will be between 150% and 200% of the tax due (known as Potential Lost Revenue or PLR), and for voluntary disclosures this will be between 100% and 200% of the PLR.

Disclosures relating to years after 2015/16 will attract penalties at the more traditional rates and will depend on a number of factors. For example a careless issue will attract a penalty rate between 0% to 60%, for deliberate the range is 30% to 140% and for deliberate and concealed issues it will be between 40% and 200%.

Where it can be demonstrated that there was a ‘reasonable excuse’ for the failure to report the overseas income and gains no penalty will be chargeable.

Our Services

HMRC Compliance Checks

Research & Development Enquiries

Voluntary Disclosures

COP8 Investigations

Annual Tax On Enveloped Dwellings

Residence And Domicile Enquiries

COP9 Investigations

HMRC Nudge Letter Campaigns

Alternative Dispute Resolution

National Minimum Wage Enquiries

Worldwide Disclosure Facility​

Settlement Negotiations

Let Property Campaign (LPC) Disclosures​

Contact Us

If you’re interested in one of our services and would like to find out more about how we can help you please get in via one of the options below.

Phone Number

0121 2853545


Company Name

Resolve Tax Limited