Worldwide Disclosure Facility

If you have undeclared income or gains, linked to offshore bank accounts, investments, properties, companies or trusts,  you need to consider if your tax affairs are in order ASAP.  HMRC now gets detailed official intelligence about overseas financial structures held by British citizens from well over 130 countries; and has received masses of data leaked from financial service providers around the world (such as the well-known recent Pandora Papers). The taxman will investigate every lead. Aggressive penalties are in force: but can be significantly reduced. The number of prosecutions is also increasing.   Historic tax problems can be cleared up by using HMRC's Worldwide Disclosure Facility; or, in cases of deliberate tax evasion, the Contractual Disclosure Facility.

What is the Worldwide Disclosure Facility?

  • The Worldwide Disclosure Facility is an opportunity to reveal previously undeclared income and gains to the taxman, without the drama of an in-depth tax investigation.
  • It's available to all UK residents with undeclared tax situations at least partly connected to an “offshore issue".
  • Discounted penalties are available for making high-quality disclosures.
  • All tax irregularities must be disclosed: not just those related to overseas matters.
  • HM Revenue and Customs WDF guidelines state: "If you're unsure about any aspect of your disclosure, you must seek professional help".
  • The Initial WDF Registration is made online: using HMRC’s Digital Disclosure Service (DDS).
  • After Initial Registration, you have 90 days to file your full and detailed disclosure: although we may be able to get a further 90-day extension in complex cases.
  • 90 days may be sufficient in the most straightforward cases - where you have all the relevant information and documents readily to hand; and are certain of the appropriate tax treatment, years involved, and rates of tax etc. But that is most unusual.  In the majority of cases we recommend that you take specialist advice before you register.
  •  Lynam Tax Enquiry Experts can register on your behalf, and prepare and submit your disclosure for you (with your approval of course).
  • Each entity concerned (e.g. individuals, companies, trusts, etc) must make a separate registration. E.g. husband & wife directors of a limited company might require 3 or more separate registrations and disclosures.
  • Full payment of all previously under-declared liabilities (to include tax, interest, and penalties) must be made at the time of the full disclosure - i.e. within 90 days of the Initial Registration (or 180 days if HMRC have agreed it's complex).
  • Time to pay arrangements may be negotiated in certain circumstances.
  • All earlier years must be included in the disclosure.
  • All outstanding Tax Returns must be filed (correctly and completely) and the tax, interest, and penalties paid; in line with the Worldwide Disclosure Facility regulations.
  • Anyone undergoing a current tax investigation can still register. But specialist advice is needed to consider if that is the best approach.
  •  The taxman says: “Criminal investigation will be reserved for those cases where HMRC needs to send a strong deterrent message or where the conduct involved is such that only the criminal sanction is appropriate".  In reality no one who has made a full disclosure has been prosecuted: so the WDF Tax Amnesty practically guarantees immunity from criminal prosecution.  But for greater certainty the Contractual Disclosure Facility should be considered.
  • Failing to register for the WDF could lead to prosecution, or the harshest levels of  penalties and naming and shaming.

What if I don’t Register for the WDF?
HMRC is already getting information from 130+ countries that have signed up to Common Reporting Standards arrangements, and has a programme to investigate every case. Some of these investigations will be on criminal lines.  The taxman has already sent out thousands of warning letters - urging taxpayers to use the WDF.

NB: Since 1 October 2018 new ultra-tough legal sanctions can apply.  These Failure To Correct penalties are detailed in our section: Penalties for Offshore Matters.

How can Lynam Tax Disclosure Experts help me?
Lynam Tax Enquiry Experts have a huge amount of experience of all the various Offshore Tax Amnesties; going back 20 years.  We have successfully had hundreds of Offshore Disclosure cases accepted by HMRC without any challenge.  We have been acknowledged by HMRC's Fraud Investigation Service unit as one of the UK’s leading specialists in using the Offshore Tax Amnesties. We can help taxpayers with offshore assets and undeclared tax liabilities clear up their historic tax problems efficiently and with minimum hassle from the authorities; and are already doing so for a significant number of clients, with the full blessing of HMRC.

Act now.  For a no obligation, confidential consultation: Call

PAUL LYNAM : 0845 643 9997  or
ANDREW NUTBROWN : 0771 877 8710



Lynam Tax Enquiry Experts HELP ME?

We specialise in managing all Tax Enquiry, Tax Disclosures & Tax Disputes with HMRC.

We will help you throughout the Tax Investigation or Disclosure and save you money, so you can concentrate on running your business and enjoying your private life.

For a helpful, sympathetic, confidential and no obligation discussion:

For a helpful, no obligation, wholly confidential discussion:

Call Andrew NOW: 07718 778710

Thanks for all your help during this process. Its been the most stressful 18 months of my life and your advice and reassurance along the way has kept me from losing my mind!  

James, Somerset, 24 August 2022.

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