Worldwide Disclosure Facility

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 is a freeview 'At a glance' guide to the Worldwide Disclosure Facility (WDF).

This allows the disclosure of a UK tax liability relating wholly or partly to an offshore issue.

• Income arising from a source outside the UK.
• Assets situated or held outside the UK.
• Activities carried on wholly or mainly outside the UK.
• Where the funds connected to unpaid tax are transferred outside the UK.

Which years?

• WDF applies for all tax years up to and including 2021-22.
• If HMRC has sent you a tax return for that year or any tax year from 2019-20 onwards which is still outstanding, you must complete the return and you must not include these tax years on this disclosure form.

You will need to self-assess your behaviour which will indicate the number of years you need to disclose. i.e. 4, 6, 12  or up to 20.

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

• Disclosures have to be made via the online Digital Disclosure Service.
• You first need to notify HMRC that you will be making a disclosure.

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

• Collate the information needed to complete the disclosure
• Calculate the final liabilities including tax, duty, interest and penalties.
• Complete the disclosure, using the unique disclosure reference number provided by HMRC when notifying.

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 took effect from 6 April 2017. The RTC window ran until 31 December 2018, after which new penalties for Failure to Correct apply. The WDF can be used to make RTC corrections. The first deadline for assessment under RTC was 6 April 2021. HMRC issued protective assessments to taxpayers who had not settled their affairs prior to this date with penalty assessments due to follow later in 2021. See Offshore Disclosures: Penalties are coming

Useful guides on this topic

Making a tax disclosure (Digital Disclosure Service)
A practical guide to making a tax disclosure using HMRC's online system.

Time limits for assessment: offshore
This is a freeview 'At a glance' guide to time limits for assessment for offshore matters.

Requirement to Correct (Offshore Evasion)
A summary of the Requirement to Correct (‘RTC’) undeclared tax relating to offshore matters and the tougher penalties that will apply for a Failure to Correct (‘FTC’).

External links

HMRC Worldwide Disclosure Opportunity

HMRC Offshore disclosure facilities