See Amit’s latest article, Is HMRC’s Worldwide Disclosure Facility working? Published on 14th August 2026 by the ACCA in their Accounting and Business Magazine.

Ten years on, the WDF is not bringing in the anticipated revenue

Amit Puri, the Managing Director of Pure Tax Investigations examines the Worldwide Disclosure Facility ten years on, for the ACCA. He said the WDF is not bringing in the anticipated revenue.

The Worldwide Disclosure Facility initiative provides individuals who have earned income or achieved gains overseas with a streamlined opportunity to bring their UK tax affairs up to date by making a voluntary disclosure through an HMRC portal. Provided the disclosures made online are full and complete, there is no need to engage further with HMRC.

But, despite a recently growing number of disclosures, and ongoing  ‘nudging’ on the part of HMRC, the trend of total annual tax receipts has been down. Amit said there was ‘more to be done’ but HMRC has secured just under £920m from WDF to date, including taxes, statutory late payment interest and penalties. The average tax secured per disclosure figure has not increased over time

The Worldwide Disclosure Facility is an example of where HMRC’s one-to-many / nudge-letters approach has been deployed, which is not as resource intensive as one-to-one enquiries.

Nudge Letters performance

There is a correlation between the number of one-to-many letters sent out by HMRC and the number of WDF disclosures received (see graphic). However, with fewer than 2,000 informal letters being sent out a month, it is low in comparison to the millions in lines of banking accounts data HMRC receives every year.

As an example, the total number of WDF disclosures received in 2018 and 2019 was 16,589, but the number of offshore accounts reported to HMRC in, say, 2017 or 2018 was around three or four million. The data exponentially eclipsed the number of disclosures made and the number of nudge letters HMRC sent out.

Surprisingly, the average tax secured per disclosure figure has not increased over time. This is despite HMRC extending the 12-year tax-assessing rule for offshore matters and offshore transfers. One would expect there to be more tax years included in WDF disclosures.

Annual tax revenues from WDF disclosures have not increased, which seems to correlate with the low numbers of nudge letters sent out. It is unclear whether this is because HMRC is unambitious, incapable of doing more or just drowning under all the banking data.

Some suggest that HMRC has ramped up the number of regular one-to-one enquiries carried out using the bulk offshore financial accounts data, but this does not appear to be the case. It seems apparent that the number of WDF disclosures being made remains directly influenced by the number of nudge letters sent by HMRC.

Who is the Worldwide Disclosure Facility for?

This is a targeted, streamlined disclosure facility for people, whether they are living in or outside of the UK, with foreign income or foreign gains, which should have been declared in their personal tax returns but was not. To be clear, an offshore issue (matter or transfer) includes underpaid or omitted tax relating to:

• income arising from a source outside the UK
• assets situated or held outside the UK
• activities carried on wholly or mainly outside the UK
• anything having effect as if it were income, assets or activities of the kind described

An international financial accounts information exchange agreement means that over 100 jurisdictions share rich financial accounts / banking data with one another, annually and automatically, without the need to make case specific requests.

Importantly, the Worldwide Disclosure Facility offers no ‘carrots’ or inducements like fixed low penalties and immunity from a criminal tax investigation, in the way that older offshore tax disclosure facilities did.

The WDF is a streamlined process through which offshore matters can be disclosed in a uniform way by those that are experienced in preparing and submitting them. The

• taxes
• interest
• penalties

that are payable, after factoring in all tax reliefs, exemptions, claims, elections and allowances, should be paid simultaneously so that cases are resolved more quickly by HMRC.

Practitioners’ takeaways

In recent months, readers may have noticed that most of HMRC’s Worldwide Disclosure Facility offshore tax related nudge letters and enquiry correspondence has been coming out of its brand new front-line directorate: Volume Compliance and Support Operations (VCSO). There is more about VCSO on our website.

Those who wait for HMRC to contact them lose the ability to make a wholly voluntary disclosure and are therefore unable to secure the minimum penalties. It is still a good time to review a client’s overseas activities, accounts, wealth etc, and ensure that UK taxes on investment income and gains are correctly calculated and disclosed.

We secure the best possible outcome for clients, based on robust knowledge about tax assessment time limits, the various offshore penalty regimes that apply and double-taxation relief quirks.