HMRC provides special tax settlement facilities and opportunities to allow taxpayers to notify undeclared income or gains over a range of different taxes. Facilities are provided via special links to enable taxpayers to settle unpaid taxes.
Disclosure services that are available in 2024/25 include:
- Cryptoasset income & gains.
- Digital Disclosure Service (covers most disclosures).
- The Contractual Disclosure Facility (Code of Practice 9): for use in cases of deliberate concealment this protects against criminal prosecution.
- Worldwide Disclosure Facility (for offshore matters).
More specialised disclosure opportunities are created at different times, including for:
For Disguised Remuneration (DR) loan schemes
- Disguised Remuneration Scheme 2020 settlement opportunity is despite its name, still open.
In a March 2024 response to the House of Common's Treasury Committee, Mr Harra of HMRC confirmed:
- When settling DR schemes with HMRC, the median settlement for individuals is £19,000 and for employers is £205,000. This will cover taxes, interest and penalties due.
- Around 40,000 individuals and 5,000 employers have not settled with HMRC.
- 1,200 taxpayers are currently discussing a settlement with HMRC.
- Around two-thirds of the individuals affected by the Loan Charge work in business services, including IT consultants, financial advisers and management consultants.
- When taking into account the DR loan they received, scheme users earn on average twice as much income as the average UK taxpayer.
- 70% of DR scheme users did so for two years or more.
- The prevalence of avoidance scheme usage was highest in London and the South East.
- HMRC do not expect anyone to pay more than half their disposable income after living expenses up to £3,000 per month. Expenditures deducted in calculating disposable income include household bills, and other reasonable expenses, for example, gym membership, healthcare plans and private school fees.
- A number of individuals are currently under criminal investigation by HMRC for offences linked to DR schemes subject to the Loan Charge. However, there have been no prosecutions of individuals for the promotion and/or operation of DR schemes subject to the Loan Charge, although one individual involved in selling DR schemes subject to the Loan Charge has been convicted for a related offence.
Medium and Large Business
Further useful links (directly to HMRC) for medium and large-sized businesses are as follows:
For medium-sized companies:
For large companies:
- Profit Diversion Compliance Facility
- Check if you need to notify HMRC about an uncertain tax treatment
See also HMRC Disclosure Opportunities