Ten years on, WDF is not bringing in the anticipated revenue, but over the past two years HMRC has secured over £100m each, and the number of disclosures is up.
“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.” — Amit Puri
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 WDF 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 are full and complete, there is no need to engage further with HMRC.
See the ACCA article, “Is HMRC’s Worldwide Disclosure Facility working?“
But, despite a recently growing number of disclosures, and ongoing ‘nudging’ on the part of HMRC, the average tax per disclosure figures have been reducing. Amit said there was ‘more to be done’ but noted that HMRC had secured just under £920m from WDF to date, including taxes, statutory late payment interest and penalties.
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 traditional one-to-one enquiries.
WDF Disclosure Statistics
| Tax Year Ended | Total Tax | Statutory Interest | Penalties | WDF Total |
| 2016 | £995,598 | £142,590 | £106,642 | £1,244,831 |
| 2017 | £25,469,102 | £4,510,624 | £3,238,601 | £33,218,328 |
| 2018 | £81,267,286 | £9,885,174 | £9,279,856 | £100,432,317 |
| 2019 | £129,578,030 | £20,569,685 | £20,774,308 | £170,922,024 |
| 2020 | £79,222,510 | £11,576,952 | £12,918,756 | £103,718,218 |
| 2021 | £48,995,945 | £4,380,074 | £16,327,984 | £69,704,003 |
| 2022 | £57,167,247 | £5,419,231 | £16,590,789 | £79,177,267 |
| 2023 | £103,718,218 | £4,073,036 | £9,840,354 | £73,917,055 |
| 2024 | £62,723,611 | £7,571,872 | £12,068,745 | £82,364,228 |
| 2025 | £75,751,029 | £13,163,398 | £12,042,106 | £100,956,533 |
| 2026 | £59,807,996 | £11,627,196 | £31,693,036 | £103,121,667 |
| £918,772,039 |
Nudge Letters performance
There was and is some a correlation between the number of one-to-many informal letters sent out by HMRC and the number of WDF disclosures they receive.
| Year | Number of WDF disclosures received | WDF Nudge Letters Sent | Average Tax per Disclosure | ||
| 2016 | 88 | £11,313.61 | |||
| 2017 | 2,833 | £8,990.15 | |||
| 2018 | 8,334 | 36,497 | £9,751.29 | ||
| 2019 | 8,255 | 34,336 | £15,696.91 | ||
| 2020 | 4,951 | 35,130 | £16,001.31 | ||
| 2021 | 4,650 | 28,613 | £10,536.76 | ||
| 2022 | 7,834 | 17,804 | £7,297.33 | ||
| 2023 | 4,627 | 23,936 | £22,415.87 | ||
| 2024 | 5,391 | 23,500 | £11,634.87 | ||
| 2025 | 5,697 | 20,000 | £13,296.65 | ||
| 2026 | 8,564 | 19,998 | £6,983.65 | ||
| Total | 52,660 | 239,814 |
However, with fewer than 2,000 informal nudge letters being sent out a month, one wonders why this is low in comparison to the millions of 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.
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. So it is still a good time to review yours and a client’s overseas accounts, activities, wealth etc, to ensure that UK taxes on investment income and gains are correctly calculated and disclosed.
We secure the best possible outcome for our clients, based on robust knowledge about offshore tax assessment time limits, the various offshore penalty regimes that apply and double-taxation relief quirks.
Amit Puri
Pure Tax Investigations
+44 20 3757 5669
info@pure-tax.com
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