Worldwide Disclosure Facility
Those with offshore income and gains can use the Worldwide Disclosure Facility (WDF) to report undeclared tax liabilities to HMRC
It is easy to make errors when it comes to receiving offshore income and gains, and it is worrying when HMRC asks questions about it
A lot of information is made available to the exchequer under the Common Reporting Standard. Apparent omissions are dealt with via “nudge letters”, which need to be handled correctly, otherwise you could incur large penalties.
In most cases, the WDF can be used to smooth out past mistakes or omissions.
You will have 90-days to prepare the disclosure and pay the tax, interest and penalty due.
It is essential to get professional advice to ensure you do not pay more than you owe. We can help you resolve matters as quickly as possible.
The Worldwide Disclosure Facility is available to individuals, companies or Trustees with offshore tax issues to disclose. Please contact Crowe's Tax Resolutions team if you would like to discuss how we can help you.
Offshore income, gains and assets should be reviewed , because:
Common misconceptions
Overseas income and gains are generally reportable in the UK by UK residents, which is often overlooked.
Common misconceptions
Legislation
The rules change regularly and are not well publicised, catching many taxpayers out.
Legislation
Anti-avoidance measures
Structures that were once tax compliant might need to resolve issues resulting from new anti-avoidance rules.
Anti-avoidance measures
Third parties
Issues can arise due to actions of third parties, e.g. an offshore trust making a transfer to a UK beneficiary.
Third parties
Common questions about the Worldwide Disclosure Facility
My foreign income and gains have been taxed overseas. Do I still need to disclose it to HMRC?
If you are UK resident, you would normally need to declare your worldwide income and gains to HMRC on an arising basis, unless you were eligible for the remittance basis.
The rules on this have changed significantly from April 2025.
I have never brought my foreign income to spend or use in the UK - do I still need to disclose it?
Maybe, it will depend on your specific circumstances.
For example, did you make a claim for the remittance basis? Is relief available under a double tax treaty?
This is why it is important to seek professional advice.
I have assets overseas, but the income and gains are minimal – surely they won’t be interested in me and go after wealthier individuals?
There is no de minimis in relation to who HMRC targets under its nudge letter campaign, so it is very likely you will be contacted at some point.
Therefore, voluntary disclosure is recommended to reduce your exposure to penalties.
What if I can’t obtain enough information to calculate my liabilities?
It is common for gaps to exist. HMRC is aware of this and will expect you to make reasonable attempts to obtain the necessary information.
You can use reasonable estimates in the event that information cannot be found.
I am registered for the WDF, but struggling to work out what I owe. Can you still help me, or is it too late?
We can still help at any point in the disclosure process.
Will HMRC seek to charge a penalty?
The short answer is yes: whenever there is a loss of tax, HMRC will see if a penalty can be charged.
Our role includes ensuring penalties are kept to the lowest level possible.
How many years will my disclosure have to cover?
This is determined by the seriousness of the behaviour which led to the under-declaration of income or gains.
It also depends on whether you have filed self-assessment tax returns and missed off the overseas income or have failed to file a return at all.
We can help you to make sure that your disclosure includes the correct number of years based on your particular circumstances.
Can I use the WDF to disclose issues that do not relate to overseas assets?
Yes, you must ensure a full disclosure of all irregularities is made, including undeclared UK income or gains as well as the offshore matters.
I’ve received a letter from HMRC saying they know I have overseas income, gains or assets: how did they know?
HMRC annually receives data via the Common Reporting Standard (CRS) from more than 100 countries.
Bank interest, dividends, income from annuities and other insurance products, account balances and proceeds from the sale of financial assets are reported annually to the customer’s ‘home’ tax territory.
How Crowe can help
We know it is not ideal being under HMRC’s spotlight. We will support you throughout every stage of the disclosure process, having helped hundreds of clients bring historic tax issues up-to-date. We will:
- act as a barrier between you and HMRC, so you do not need to speak directly with HMRC
- review the background of your case and identify all issues that need to be disclosed
- advise on the most appropriate steps to make a full disclosure, to reduce the possibility of HMRC asking follow-up questions
- calculate the underpaid tax whilst ensuring all legitimate claims for tax reliefs/allowances are considered
- advise you on the likely penalty position and consider all mitigating factors to reduce penalties as low as possible
- liaise with third parties to obtain the data that is relevant to your disclosure
- ensure that HMRC does not overstep the mark, for example, by making requests for data that HMRC is not entitled to.
Our award-winning team will help resolve matters as soon as possible. Our experts are approachable, professional, and provide a discreet and comprehensive service.
Book a free consultation
We are professional advisors who specialise in helping our clients with HMRC Disputes, Investigations and Disclosures.
If you would prefer to speak to us, please call our free confidential helpline +44 (0)800 656 9900.
We're here to help
Our experienced and award-winning Tax Resolutions team can help you navigate the WDF process and ensure you meet your obligations.
