Worldwide Disclosure Facility
The Worldwide Disclosure Facility (WDF) was launched in September 2016 and is open to anyone who wants to disclose a UK tax liability that relates wholly or partly to an offshore issue.
An offshore issue includes unpaid or omitted tax relating to:
- income arising from a source in a territory outside the UK;
- assets situated or held in a territory outside the UK;
- activities carried on wholly or mainly in a territory outside the UK;
- anything having effect as if it were income, assets or activities of a kind described above.
Under the legislation certain financial institutions, tax agents and tax advisers in the UK are required to write to certain taxpayers with money or assets abroad. The notification letters must be sent to relevant clients between 30 September 2016 and 31 August 2017.
Any taxpayers that receive a ‘notification letter’ need to check their tax affairs are up-to-date. These letters are being sent to some taxpayers resident in the UK who have money or assets overseas. For example, a bank that has provided a UK resident with an overseas bank account may be required to send such a letter.
If you have received a letter from HMRC or have specific concerns we would be happy to discuss your options. It is important to note that receipt of a letter in no way implies that any tax avoidance has taken place. However, those with undeclared foreign income or assets will need to make a disclosure to HMRC using the WDF.
Unlike previous disclosure opportunities, the new WDF does not offer any special terms for settling tax affairs and in most cases any interest and penalties levied will be charged in full. HMRC’s guidance on making a disclosure has recently been updated.