UK residence history
UK residence, overseas residence and relevant split-year positions are reconstructed before foreign income is taxed.
The Worldwide Disclosure Facility is HMRC's disclosure route where a UK tax liability relates wholly or partly to an offshore issue. It can involve foreign bank interest, dividends, overseas property, foreign investments, capital gains, trusts, pensions or other assets and activities outside the UK.
The existence of money or property overseas does not by itself mean UK tax was due. Residence, domicile under historic rules, the post-2025 foreign income and gains regime, double-tax relief, remittances, treaty provisions and the tax year involved may all affect whether there is actually a UK liability to disclose.
Give us the country, type of income or asset, approximate years and whether HMRC has already contacted you. Sensitive records can follow through secure onboarding.
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The first task is to establish whether the foreign income, gain or asset created a UK tax liability at all, before deciding which years and amounts belong in the disclosure.
Foreign income is not automatically taxable in the same way for every taxpayer or every tax year. Residence status, historic remittance-basis rules, the foreign income and gains regime from April 2025, treaty provisions and foreign tax already paid may materially change the UK calculation.
The engagement can cover the offshore issue alone or a wider disclosure where connected onshore UK liabilities must also be brought up to date.
UK residence, overseas residence and relevant split-year positions are reconstructed before foreign income is taxed.
Interest, dividends, rental income, pensions and other overseas income are analysed year by year.
Historic acquisitions, disposals, foreign currency values and allowable costs are reconstructed where overseas assets were sold.
Tax paid abroad and relevant treaty provisions are reviewed to avoid taxing the same income twice where relief is available.
Normal, offshore and deliberate-behaviour assessment periods are considered before deciding which years remain capable of assessment.
The final disclosure brings together the tax liability, late-payment interest, penalty analysis and formal offer to HMRC.
The offshore tax analysis is completed before the final penalty position so that the disclosure is based on the liability actually due under UK law.
We identify countries, assets, income sources, residence history, tax returns and prior HMRC contact.
Where WDF is appropriate, HMRC is notified through the disclosure service and issues the disclosure reference.
Taxable foreign income and gains, foreign tax relief, interest and penalties are calculated year by year.
The disclosure and formal offer are submitted with payment or the relevant payment arrangement within the applicable timetable.
HMRC defines the facility broadly. A UK tax liability can qualify where it relates wholly or partly to foreign income, assets, activities or a relevant offshore transfer.
Interest, dividends, overseas property rents, pensions and other income arising from sources outside the UK can create an offshore tax issue.
Foreign land, securities, investment accounts and other assets can create UK Income Tax, Capital Gains Tax or Inheritance Tax consequences.
Business, investment or other activities carried on wholly or mainly outside the UK can fall within the facility where they produce a UK tax liability.
A liability can also involve an offshore transfer where funds connected with unpaid UK tax are transferred outside the UK.
The WDF does not require the taxpayer to be UK resident at the time of disclosure. HMRC's current guidance confirms that a non-UK resident can still use the facility where the eligibility conditions are met and a UK tax liability needs to be disclosed.
HMRC's current guidance explains which offshore liabilities can be disclosed and how the facility operates.
Official WDF guidance ↗HMRC's overview describes offshore income, assets, activities and transfers that can bring a UK tax liability within WDF.
Official offshore disclosure guidance ↗The disclosure period should be established from the statutory assessment rules rather than simply assuming every foreign account must be reconstructed for twenty years.
WDF is not the same as the COP9 Contractual Disclosure Facility. HMRC's WDF guidance expressly states that a taxpayer using WDF may still be liable to criminal prosecution. Where deliberate behaviour is involved and the contractual protection available under CDF may be relevant, the appropriate disclosure route should be considered before WDF is used.
HMRC's Compliance Handbook explains the twelve-year offshore assessment rule and when the longer deliberate-behaviour period applies.
Offshore time-limit guidance ↗Historic offshore non-compliance can in some circumstances engage the separate failure-to-correct penalty regime, which requires case-specific analysis rather than being assumed for every WDF disclosure.
Failure-to-correct guidance ↗An offshore disclosure can involve residence, foreign tax credit, historic disclosure procedures or an existing HMRC investigation, so the correct supporting service depends on the underlying facts.
The correct disclosure period and liability depend on residence, behaviour, the type of offshore matter and the UK tax rules applying to each year.
It is HMRC's disclosure facility for UK tax liabilities relating wholly or partly to offshore matters, including relevant foreign income, gains, assets, activities and offshore transfers.
After HMRC acknowledges the notification, the taxpayer normally has 90 days to gather the records, calculate the tax, interest and penalties and submit the completed WDF disclosure.
No. The underlying income and the taxpayer's UK tax status must be considered. A foreign account by itself does not establish that UK tax was underpaid.
Potentially. HMRC's current WDF guidance specifically addresses taxpayers who receive letters about money or assets abroad and, after reviewing their affairs, discover a UK tax liability requiring disclosure.
A twelve-year extended assessment period can apply to qualifying Income Tax, Capital Gains Tax and Inheritance Tax involving offshore matters or certain offshore transfers. It is subject to detailed statutory conditions and exceptions, so it should not be applied automatically to every case.
Yes in relevant cases involving deliberate behaviour. Other twenty-year provisions can also apply in particular circumstances, so the disclosure period should be determined from the actual facts rather than selected simply because the issue is offshore.
No. HMRC's WDF terms expressly reserve the possibility of criminal investigation or prosecution. The Contractual Disclosure Facility under COP9 is a different procedure with specific contractual terms for disclosed deliberate behaviour.
Foreign tax already paid should be reviewed before the UK liability is calculated. A double tax treaty or foreign tax credit may reduce the UK tax due, depending on the income, country and circumstances.