Voluntary disclosures

Voluntary disclosures are made to HMRC to pre-empt a potential HMRC investigation and to minimise the overall liabilities.  It is never too late to approach HMRC to make a voluntary disclosure, even if the omissions were deliberate and were many years ago.

We advise on and prepare the full range of voluntary disclosures to HMRC including those made:

  • under the Worldwide Disclosure Facility (“WDF”) of omissions relating to overseas assets and income (read more here);
  • of general matters through the Digital Disclosure Service;
  • under HMRC Code of Practice 8 (“COP 8”) of complex matters involving large potential amounts of tax;
  • under HMRC Code of Practice 9 (“COP 9”) where serious amounts of tax were deliberately omitted and a guarantee is sought from HMRC of non-prosecution – subject to full disclosure under the terms of the Contractual Disclosure Facility (“CDF”) (read more here);
  • by corporate groups – including those made under the Profit Diversion Compliance Facility (“PDCF”);
  • upon receiving a “nudge letter” from HMRC suggesting HMRC believe an omission might have occurred – including in relation to overseas assets and income, domicile and cryptocurrencies;
  • to fully clarify the historic tax position in light of legal disputes and divorces – including situations where tax related contentions might have been made in court.