Worldwide Disclosure Facility WDF in London

The Worldwide Disclosure Facility (WDF) was introduced by HMRC in September 2016. This offered an opportunity to voluntarily disclose undeclared offshore income or gains. Parallel to this, HMRC continued receiving information related to offshore income and gains from over 100 countries under Common Reporting Standard (CRS) agreement. Information from CRS has greatly increased HMRC's ability to trace and detect undeclared offshore income and gains HMRC introduced Requirement to Correct (RTC) rules which required taxpayers with undeclared offshore income and gains to make a disclosure by 30 September 2018. Failure to meet this deadline would be considered as a Failure to Correct (FTC). Accordingly, any disclosure submitted after 30 September 2018 would be subject to tougher Failure To Correct (FTC) penalties with a minimum penalty of 100% and a maximum penalty of 200% of underpaid tax.

Who is Eligible?

If you are subject to UK tax and have undeclared offshore income or gains, you can use the Worldwide Disclosure Facility (WDF) to correct your tax position. This could include unpaid tax on the following.

  • Income which has been earned from a non-UK territory
  • Assets held in offshore territories
  • Activities carried out outside the UK

It is advisable to disclose before being prompted as HMRC will offer more favourable terms and lower penalties for an unprompted disclosure.

Worldwide Disclosure Facility Disclosure Process Explained

If you are someone who wants to make an unprompted disclosure or have been prompted by HMRC to do so, there are several steps to be followed.

The first step is to inform HMRC of your intention to disclose. This is done by submitting an initial notification using HMRC's Digital Disclosure Service (DDS).

HMRC will then send you a letter acknowledging your notification and allow you 90 days to finalise and submit the disclosure.

This can be a daunting a complex task as you are required to submit a complete disclosure of underpaid tax, interest and assess the correct level of penalties.

As part of the process, you will be required to self-asses behaviour that resulted in failure to disclose. Your behaviour along with the jurisdictions of your undeclared income/gains will determine the correct level of penalties to be applied. The self-assessment of your behaviour will also determine the number of years you need to disclose.

To negotiate lower penalties, it is important to offer full co-operation and submit an accurate disclosure. Failure to do so can have serious consequences such as higher penalties, criminal investigation or even worse, your name being published online.

You should therefore seek advice from professionals with experience, knowledge and detailed understanding of tax rules.

How we can help with the disclosure

Churchill Tax Investigation in London specialise in WDF disclosures and has helped a large number of clients in making disclosures through WDF. Our team consist of Senior Ex-HMRC tax inspectors and Chartered Tax Advisers who are very experienced and familiar with this process. All disclosures submitted by our firm have been accepted by HMRC and we have used our knowledge and expertise to minimise overall liabilities for our clients

Our team of tax experts can advise clients on whether they need to raise any technical issues which may influence the disclosure such as domicile or residence status because these must be disclosed

As part of the disclosure, you will also need to declare the maximum amount of assets held outside the UK covering the last five years. This must include personal goods such as jewellery, investments and cash

When the declaration is made, so too must the payment. Where required a Time to Pay agreement can be reached and this is something else that Churchill Tax Investigation in London can help you with.

In summary we will do the following:

  • Take ownership of the voluntary disclosure process
  • Advise clients on best possible options for voluntary disclosure
  • Communicate with client's accountants (if needed)
  • Communicate with HMRC
  • File the disclosure report
  • Agree the amount payable with HMRC including penalties


For further information on our specialist tax investigation services for the Worldwide Disclosure Facility, please contact our friendly, experienced and knowledgeable team for a confidential discussion.