HMRC Nudge Letters

HMRC nudge letter help

If an HMRC nudge letter has arrived, we review it, check your records against what HMRC is likely to hold, and handle any disclosure that is needed from start to finish.

Why have you received a nudge letter?

  • A nudge letter is HMRC prompting you to check your own tax affairs, usually because third-party data suggests something may be missing from your returns.
  • Common triggers are overseas bank accounts and investments, rental income and cryptoasset activity.
  • Over 100 countries now exchange financial account information with HMRC under the Common Reporting Standard (gov.uk, Worldwide Disclosure Facility guidance), so a letter about money or assets abroad normally means HMRC already holds data with your name on it.
  • What the letter means, what the certificate of tax position is, and the mistakes people make in the first week are covered in our guide, what to do when an HMRC nudge letter arrives. This page is about what we do when you bring the letter to us.

What do we do when you bring us the letter?

Four things, in order.

First, we read the letter and identify what prompted it and what HMRC is actually asking for, including any certificate of tax position, which we advise on before anything is signed.

Second, we check your records for the years in question against your filed returns.

Third, we give you a straight answer: either your affairs are correct and we prepare a considered reply saying so, or there is something to put right.

Fourth, where a disclosure is needed, we choose the correct facility, prepare the figures for tax, interest and penalties, submit the disclosure and see it through to HMRC's acceptance.

The facility choice matters. Offshore income and gains go through the Worldwide Disclosure Facility. Undeclared rental profits go through the Let Property Campaign. Cryptoasset liabilities have their own route, covered on our crypto tax disclosure page. Other liabilities use HMRC's Digital Disclosure Service.

How does the engagement run?

You send us the letter, ideally before we first speak. We agree the scope and fee basis at the outset. From there:
  • You authorise us to deal with HMRC directly (form COMP1a for disclosures), and from that point the correspondence comes to us, not to you.
  • We give you a document checklist.
  • We build the disclosure computations year by year.
  • We agree the behaviour position with you honestly.
  • We handle HMRC's questions until the matter is closed.

What does it cost to ignore the letter?

Nudge letters do not lapse. If HMRC receives no response and later opens a compliance check or enquiry, any disclosure then made is prompted rather than voluntary, which places it in a higher penalty range (gov.uk compliance factsheets CCFS7a and CCFS11).
  • HMRC's assessment reach runs to 4 years as standard.
  • It extends to 6 years for carelessness.
  • It runs up to 20 years for deliberate failures.
  • Interest accrues daily on unpaid tax from the original due date.
  • A disclosure made after that point is prompted, which reduces the penalty mitigation available.

Frequently asked questions

A nudge letter is a one-to-many prompt rather than a formal enquiry. HMRC sends it when third-party data, such as financial account information exchanged by over 100 countries under the Common Reporting Standard, does not appear to match what is on your tax returns. The letter asks you to check your affairs and, in many cases, to complete a certificate of tax position. It does not tell you exactly what HMRC holds, and it does not mean HMRC has concluded anything yet.
There is no penalty for the letter itself, but silence is a poor strategy. HMRC issued the letter because it holds data, and if no response arrives it can move to a compliance check or a formal enquiry, at which point any disclosure becomes prompted and sits in a higher penalty range. The sensible sequence is to check the years in question properly, then respond once you know whether anything is owed. We do that checking before anything is sent.
Not before your affairs have been reviewed. The certificate asks you to declare that your tax affairs are correct and complete, and signing an inaccurate declaration is treated far more seriously than the original error it conceals. If a review shows a liability, the better course is usually a disclosure through the correct facility rather than a certificate. We advise on the certificate as the first step of every nudge letter engagement.
Then the right response is a clear, evidenced reply saying so, not silence and not an over-share. A proportion of nudge letters land on people whose affairs are in order, for example where the offshore account produced no taxable income or the income was covered by allowances and correctly reported. We prepare the reply so that it answers the letter without inviting a wider review.
The data that generated the letter stays on HMRC's systems. HMRC can open a compliance check or an enquiry, assess up to 4 years as standard, 6 years where it considers you careless and up to 20 years where the failure was deliberate, and charge interest daily from each original due date. A disclosure made after that point is prompted, which reduces the penalty mitigation available. Coming forward first is almost always the cheaper sequence.
It depends on the source of the untaxed income or gains. Offshore matters go through the Worldwide Disclosure Facility, undeclared UK rental profits through the Let Property Campaign, cryptoasset liabilities through HMRC's cryptoasset disclosure service, and most other matters through the Digital Disclosure Service. Where the behaviour was deliberate, Code of Practice 9 and the Contractual Disclosure Facility may be the safer route because it carries protection from criminal investigation for what is disclosed. Choosing the facility is part of the engagement, not something you need to decide before calling.

Who handles nudge letter cases?

This work is led personally by senior managers. The wider team prepares the computations and document schedules under oversight throughout the engagement. Send the letter through and call 020 8554 2135, or email info@visionconsulting.co.uk. First conversations are confidential and at no cost. This is general information, not advice. Your position depends on your circumstances. Speak to us before acting.