After much speculation, HMRC has announced its new disclosure facility: the Worldwide Disclosure Facility (WDF).

The WDF is the follow-up disclosure facility to the now-ceased Liechtenstein, Isle of Man, Jersey and Guernsey Disclosure Facilities.

Who is eligible?

Anyone wishing to disclose a UK tax liability relating either wholly or partly to an offshore issue may disclose via the WDF.

Why should I use the WDF?

HMRC has stated that the WDF is the final chance to put things right for those individuals with outstanding UK tax liabilities on undeclared offshore money or assets.

This last chance comes before HMRC starts to receive an unprecedented amount of data on offshore account held by individuals with a footprint in the UK.

Sanctions facing those who have not come forward already or use the WDF will be far tougher in the future, with the potential prospect of minimum penalties of 100% of the tax due and an increased chance of criminal prosecution.

When will I be able to disclose via the WDF?

Any person wishing to disclose via the WDF can notify their intention to disclose to HMRC as of 5 September 2016, which is when it goes live.

The final disclosure, enclosing all details of previously undeclared UK tax liabilities, must be provided to HMRC within 90 days of notification.

What if I don't have an undisclosed UK tax liability relating to an offshore issue?

Whilst you may not use the WDF, you are still able to approach HMRC to make a disclosure of any other matters relating to a UK tax liability. Making a proactive disclosure to HMRC, where appropriate, should normally lead to lower penalties being charged if your disclosure has not been prompted by HMRC action.

How can Grant Thornton UK help?

Grant Thornton UK's National Tax Investigations team have considerable experience in making disclosures both via previous disclosure facilities and also by directly approaching HMRC.

In making any disclosure to HMRC, it is strongly recommended that you seek professional advice in both computing any liabilities due and making any representations to HMRC to seek to minimise your financial exposure.

Director, Head of Tax Investigations David Francis

+44 (0)121 2325 425

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