HMRC launch Worldwide Disclosure Facility

HMRC launch Worldwide Disclosure Facility

The facility will allow taxpayers to correct past irregularities before the new ‘Requirement to Correct’ is introduced.

Associate Partner

KPMG in the UK


Also on

The Government has recently published a new consultation document which proposes a Requirement to Correct (RTC). UK taxpayers with offshore holdings could soon be subject to new legal obligations to correct UK tax irregularities, with significant sanctions if they fail to comply on or before 30 September 2018. Ahead of the new sanctions being introduced, HMRC have also launched a new Worldwide Disclosure Facility (WDF), to enable taxpayers to correct past irregularities in their tax affairs. 

By 30 September 2018 HMRC will be receiving Common Reporting Standard (CRS) data from around 100 countries, which will allow them to identify and pursue those who have not come forward to regularise their affairs. 

Any person who is found to have failed to have corrected their affairs will be subject to a new set of sanctions. Under one proposal, this would include penalties in the range of a minimum of 100 percent up to 200 percent, as well as a 10 percent asset based penalty and ‘naming and shaming’ of those who failed to correct. 

It is envisaged that the RTC will encourage taxpayers to review their affairs and take advice as appropriate to assure themselves that their offshore interests are tax compliant and if not to correct this.

HMRC have also announced a new Worldwide Disclosure Facility to enable those who may be affected to come forward to settle their tax affairs, This was launched on 5 September 2016.

The WDF requires the disclosure of UK tax liabilities that relate wholly or partly to an offshore issue and requires:

  • A notification to disclose;
  • Completion of the disclosure within 90 days of the date the notification is confirmed; and
  • Payment of tax, interest and penalties by the disclosure submission date.

The WDF provides no immunity from prosecution, and is not the only way to make a disclosure to HMRC.


If you would like to discuss these recent developments and any impact they may have on your tax affairs, then please get in touch with your usual KPMG Private Client contact or the named contacts.

Derek Scott

Tel: +44 20 73112618


Michael Pape

Tel: +44 20 73112173


Tax Matters Digest

Tax Matters Digest

View KPMG's weekly newsletter covering the latest issues in taxation and government announcements relating to tax matters.

Connect with us


Request for proposal



KPMG’s new-look website

KPMG’s new-look website