HMRC's Worldwide Disclosure Facility (WDF) opened on 5 September 2016. It allows the disclosure of a UK tax liability relating wholly or partly to an offshore issue.

This includes:

Which years?

Will need to self-assess your behaviour which will indicate the number of years you need to disclose. i.e. 4, 6 or up to 20.

Anyone wishing to disclose a UK tax liability in relation to the above is eligible to use the WDF:

Once you have notified HMRC, you will have 90 days to:

In June 2017 HMRC announced that this 90 day deadline can be extended to 180 days where the disclosure is exceptionally complex. To whether your case qualifies for this call HMRC on 0300 322 7012.  

Complex issues can also be clarified by obtaining non-statutory clearance under Annex E of the Non-statutory clearance procedure.

As part of the disclosure, you will have to self-assess your behaviour in relation to your tax affairs, ranging from careless to deliberate and concealed.

In August 2016 HMRC launched a Consultation on offshore evasion on proposals to require any person with undeclared UK tax liabilities in respect of offshore interests to correct that situation by disclosing the relevant information to HMRC.  This disclosure can be made through the WDF.

Following the consultation, the Requirement To Correct (RTC) legislation was included in Finance (No2) Act 2017, which takes effect from 6 April 2017. The RTC window runs until 30 September 2018, after which new penalties for Failure to Correct will apply. The WDF can be used to make RTC corrections.


HMRC Worldwide Disclosure Opportunity

HMRC Offshore disclosure facilities


June 2017 added years for disclosure and HMRC extend the 90 day time limit.