Worldwide Disclosure Facility to be launched on 5 September

By Steven Pinhey, Tax Director

HM Revenue & Customs (‘HMRC’) have recently announced that a Worldwide Disclosure Facility (‘WDF’) is to be launched on 5 September to allow taxpayers with offshore undisclosed income and gains to come forward and regulate their offshore tax affairs. The facility is likely to run until at least September 2017 when HMRC will start receiving information from the 54 early adopters of the Common Reporting Standard (‘CRS’). The CRS will provide HMRC will significant data on taxpayers with offshore accounts.

Steven Pinhey, our Head of Tax Disputes and Resolutions commented ‘Ever since the early closure of the Liechtenstein and Crown Dependency Disclosures, the profession has been waiting for the announcement of HMRC’s ‘last chance’ opportunity to allow taxpayers to regulate their affairs. Whilst there is very little detail available at present, it is clear that this will not be an opportunity with special terms, rather a chance for taxpayers to regulate their tax affairs before further punitive sanctions are imposed in accordance with the new legislation and HMRC’s consultation on ‘Tackling offshore tax evasion’. It also appears certain now that there will be no immunity from prosecution within the WDF, which of course was available under the previous Liechtenstein Disclosure Facility.’

Steven and his team have extensive experience of dealing with past disclosure opportunities as well as generally representing clients in complex negotiations with HMRC. He would be happy to talk through your options if you have current or potential tax issues with HMRC. Steven Pinhey can be contacted on 020 7490 7766 or email

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