Worldwide Disclosure Facility launched
At the end of August, HMRC announced a new Worldwide Disclosure Facility (WDF) would be launched on 5 September 2016. The WDF, first announced at Budget 2015, allows those with outstanding tax to pay (relating wholly or in part to an offshore issue) to put their affairs in order. This replaces previous country- specific amnesties such as agreements with Switzerland and Liechtenstein.
HMRC waited until the launch date of the scheme to release some further details. As expected, it has been confirmed that the new facility will offer no special terms for settling liabilities. Any tax due must be paid in full together with interest. There will also be a minimum penalty of 30% together with the possibility of criminal prosecution.
From the 5 September 2016, HMRC will also consider how long it has taken for a disclosure to be made when calculating the amount of penalties due.
Jennie Granger, HMRC, Director General of Enforcement and Compliance, said:
‘We’ve closed old disclosure facilities, increased penalties, and ramped-up our powers to tackle evaders and those that help others evade. Alongside this, international cooperation through global tax transparency is making it easier for us to catch evaders, as we increasingly receive more information about financial assets which people had hoped would remain hidden. Our message couldn’t be clearer: there are no safe havens left for tax evaders and no-one should be in any doubt that the days of hiding money offshore with impunity are gone.’
The WDF will be the final chance to come forward before HMRC begins to use the information obtained from over 100 countries on a multilateral basis under the Organisation for Economic Co-operation and Development Common Reporting Standard (CRS). New sanctions which are expected to be even more onerous will be introduced after 30 September 2018.
HMRC’s newly published guidance includes further details on making a notification and disclosure, the terms of the facility as well instructions as to how to seek clarification of complex issues before submitting a disclosure.