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WDF

Worldwide Disclosure Facility accountant

We prepare and submit Worldwide Disclosure Facility (WDF) disclosures end to end: notification, the 90-day disclosure, the behaviour self-assessment, the tax, interest and penalty computations, and HMRC's follow-up questions through to acceptance. Correct as at 17 August 2026.

What is the situation?

Something offshore was never taxed in the UK: interest on a foreign account, rental income from a property abroad, a gain on an overseas asset, or income routed through an offshore structure. Often the trigger is an HMRC letter about money or assets abroad, driven by data from the more than 100 countries exchanging financial account information under the Common Reporting Standard (gov.uk, WDF guidance). The WDF is HMRC's route for disclosing any UK tax liability that relates wholly or partly to an offshore issue.

How does the WDF actually work?

You notify HMRC through the Digital Disclosure Service. HMRC issues a disclosure reference number, and from the date you receive the notification acknowledgement you have 90 days to submit the full disclosure and pay what you owe (gov.uk, WDF guidance). Complex cases can request a further 90 days, giving up to 180 in total. Each person discloses separately, so spouses each make their own disclosure covering their share. The number of years you must disclose is set by your behaviour: broadly 4 years where reasonable care was taken, 6 years where there was carelessness, and up to 20 years where the failure was deliberate. Background reading sits in our guide, offshore income and the Worldwide Disclosure Facility.

Why does the behaviour self-assessment matter so much?

The WDF requires you to categorise your own behaviour, and that single judgement drives the years disclosed and the penalty range applied. HMRC states plainly that an incorrect self-assessment can lead to civil intervention or criminal prosecution, and that the terms of the facility are not guaranteed for inaccurate disclosures (gov.uk, WDF guidance). This is the part people get wrong on their own. We assess the behaviour question against the actual facts and the case law standard for carelessness and deliberateness, and we document the reasoning so the disclosure withstands testing.

What do we do, step by step?

We review the years and sources involved, reconstruct the income and gains from statements where records are thin, compute UK tax year by year, calculate daily interest from each original due date, and apply the correct offshore penalty rates by territory category. We submit the notification and the disclosure, manage the payment arrangements where full payment on submission is not possible (which must be agreed with HMRC before the disclosure goes in), and deal with the acknowledgement and any evidence requests. HMRC acknowledges a completed disclosure within 15 days and aims to state its course of action within 90 days of that acknowledgement (gov.uk, WDF guidance).

What if the failure was deliberate?

The WDF is not always the right vehicle. Where there is deliberate conduct that HMRC could treat as fraud, the Contractual Disclosure Facility under Code of Practice 9 offers protection from criminal investigation for what is disclosed, and the choice between the two routes should be made deliberately, not by default. That decision is exactly what the first conversation is for: Code of Practice 9.

Who handles WDF disclosures?

WDF engagements are led personally by Ghulam Alahi, Managing Director, who has more than 25 years' experience of HMRC enquiry work, with the wider team preparing computations and schedules under his direction.

Call 020 8554 2135 or email info@visionconsulting.co.uk. First conversations are confidential and at no cost.

Frequently asked questions

The WDF is HMRC's standing route for disclosing a UK tax liability that relates wholly or partly to an offshore issue: foreign income, assets held abroad, activities carried on abroad, or funds connected to unpaid UK tax that were moved offshore. It opened on 5 September 2016 after HMRC closed its incentivised offshore facilities, and since 1 October 2018 it has operated alongside the tougher Requirement to Correct sanctions. It carries no special penalty discount; you calculate interest and penalties under the existing legislation, but a voluntary disclosure generally sits in a lower penalty range than one HMRC prompts.

You have 90 days from the date you receive HMRC's notification acknowledgement to submit the completed disclosure and pay what you owe. Complex cases can request a further 90 days from notification, giving up to 180 days in total, by contacting HMRC's Offshore Disclosure Facility helpdesk. If you cannot pay in full on submission, payment arrangements must be agreed with HMRC before the disclosure is submitted, not after.

The assessment periods are set in statute and follow behaviour. Broadly, 4 years where you took reasonable care, 6 years where the underpayment arose from carelessness, and up to 20 years where the failure to notify or the inaccuracy was deliberate. Some Inheritance Tax disclosures can run longer than 20 years and cannot go through the online service, so they are handled directly with HMRC. Getting the behaviour category right is what fixes the year count, which is why it should not be guessed.

The disclosure form requires you to select the behaviour that caused the underpayment, from reasonable care through carelessness to deliberate conduct. That selection determines both the number of years disclosed and the statutory penalty range, and HMRC treats it as an integral part of the disclosure. An incomplete or incorrect self-assessment can lead to a civil intervention or criminal prosecution, and HMRC will not guarantee the facility's terms for an inaccurate disclosure. We assess it against the facts and document the reasoning.

Offshore penalties are higher than onshore ones and depend on the territory involved and the behaviour, using HMRC's territory categorisation and factsheet CCFS17. Under the parallel Let Property Campaign guidance HMRC states penalties can reach 100% of the tax for UK liabilities and 200% for offshore liabilities. Where someone could have disclosed through an earlier offshore facility and waited more than around 3 years, HMRC is unlikely to reduce the penalty by more than 10 percentage points above the statutory minimum. Voluntary, complete and cooperative disclosures sit at the lower end of each range.

If the conduct was deliberate and HMRC could characterise it as fraud, the Contractual Disclosure Facility under Code of Practice 9 gives contractual protection from criminal investigation for what you disclose, which the WDF does not. The WDF suits offshore liabilities arising from error, misunderstanding or carelessness, and plenty of deliberate cases still settle through it, but the route should be chosen on the facts. That judgement is the first thing we form in a WDF engagement, before anything is submitted.

This is general information, not advice. Your position depends on your circumstances. Speak to us before acting.