HMRC launch Worldwide Disclosure Facility (‘WDF’)

By Steven Pinhey, Tax Director

As expected, HMRC launched the Worldwide Disclosure Facility on Monday 5 September.

Who Can Use the WDF
The facility is open to anyone who wants to disclose a UK tax liability that relates wholly or partly to any offshore issue and includes:

  • Income arising from a source outside the UK
  • Assets situated or held outside the UK
  • Activities carried on wholly or mainly outside the UK
  • Funds connected to unpaid or omitted UK tax transferred to a territory outside the UK

How do I Use the WDF
The intention to disclose under the WDF must be undertaken using the Digital Disclosure Service. 

However, once you have notified HMRC of your intention to disclose you will only have 90 days to complete the disclosure including calculate the tax, interest and penalties.

We would advise that before you register an intention to disclose, that you first speak to us as our team at Lubbock Fine have extensive experience in dealing with past disclosure opportunities as well as generally representing clients in complex negotiations with HMRC. 

What to do next
Our Head of Tax Disputes and Resolution, Steven Pinhey would be happy to talk through your options if you have current or potential tax issues with HMRC that need resolving. Steven Pinhey can be contacted on 020 7490 7766 or email


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