Specialist UK tax advice for Manchester individuals, landlords, directors and businesses
Offshore tax disclosures

Worldwide Disclosure Facility Accountant for Offshore Income, Gains and Assets

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.

Worldwide Disclosure Facility HMRC

offshore tax disclosure UK

90 day WDF deadline

foreign income disclosure HMRC

Offshore disclosure enquiry

Tell us about the foreign income, gain or asset

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.

Prefer to call? 0800 135 7323

Direct answer

What Does a Worldwide Disclosure Facility Accountant Review First?

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.

The practical answer

A Worldwide Disclosure Facility Accountant Should Establish UK Taxability Before Calculating Penalties

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.

Residence UK residence and, where relevant, split-year treatment are established for each tax year.
UK taxability The foreign income or gain is tested under the UK rules applying to the particular year.
Foreign tax Tax paid overseas is reviewed for treaty relief or foreign tax credit where available.
Behaviour The reason the liability was missed affects the disclosure period and potential penalties.
Service scope

Worldwide Disclosure Facility Work We Can Review

The engagement can cover the offshore issue alone or a wider disclosure where connected onshore UK liabilities must also be brought up to date.

01 / RESIDENCE

UK residence history

UK residence, overseas residence and relevant split-year positions are reconstructed before foreign income is taxed.

02 / INCOME

Foreign income

Interest, dividends, rental income, pensions and other overseas income are analysed year by year.

03 / GAINS

Foreign capital gains

Historic acquisitions, disposals, foreign currency values and allowable costs are reconstructed where overseas assets were sold.

04 / RELIEF

Foreign tax credit

Tax paid abroad and relevant treaty provisions are reviewed to avoid taxing the same income twice where relief is available.

05 / YEARS

Disclosure period

Normal, offshore and deliberate-behaviour assessment periods are considered before deciding which years remain capable of assessment.

06 / SETTLEMENT

Tax, interest and penalties

The final disclosure brings together the tax liability, late-payment interest, penalty analysis and formal offer to HMRC.

How the engagement works

From Offshore Records to a Complete Worldwide Disclosure Facility Submission

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.

01 / FACTS

Establish the offshore history

We identify countries, assets, income sources, residence history, tax returns and prior HMRC contact.

02 / NOTIFY

Notify under WDF

Where WDF is appropriate, HMRC is notified through the disclosure service and issues the disclosure reference.

03 / CALCULATE

Reconstruct UK liabilities

Taxable foreign income and gains, foreign tax relief, interest and penalties are calculated year by year.

04 / DISCLOSE

Submit and settle

The disclosure and formal offer are submitted with payment or the relevant payment arrangement within the applicable timetable.

Offshore issues

The Worldwide Disclosure Facility Covers More Than Foreign Bank Accounts

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.

01 / INCOME

Foreign-source income

Interest, dividends, overseas property rents, pensions and other income arising from sources outside the UK can create an offshore tax issue.

02 / ASSETS

Assets held overseas

Foreign land, securities, investment accounts and other assets can create UK Income Tax, Capital Gains Tax or Inheritance Tax consequences.

03 / ACTIVITIES

Activities outside the UK

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.

04 / TRANSFERS

Funds transferred offshore

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.

Worldwide Disclosure Facility eligibility

HMRC's current guidance explains which offshore liabilities can be disclosed and how the facility operates.

Official WDF guidance ↗
Years and penalties

Worldwide Disclosure Facility Accountant Review of the 90-Day Deadline and Offshore Time Limits

The disclosure period should be established from the statutory assessment rules rather than simply assuming every foreign account must be reconstructed for twenty years.

90 days After receiving HMRC's notification acknowledgement, the taxpayer normally has 90 days to complete the WDF disclosure and calculate the tax, interest and penalties.
Up to 12 years A twelve-year assessment period can apply to qualifying offshore Income Tax, Capital Gains Tax and Inheritance Tax matters, subject to the statutory conditions and exceptions.
Up to 20 years Where the loss of tax was brought about deliberately, the longer twenty-year assessment period can apply.
Full disclosure The WDF terms require full disclosure of previously undisclosed UK liabilities, including relevant onshore liabilities discovered while preparing the offshore disclosure.

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.

Offshore assessment periods

HMRC's Compliance Handbook explains the twelve-year offshore assessment rule and when the longer deliberate-behaviour period applies.

Offshore time-limit guidance ↗

Failure to correct penalties

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 ↗
Frequently asked

Worldwide Disclosure Facility Questions

The correct disclosure period and liability depend on residence, behaviour, the type of offshore matter and the UK tax rules applying to each year.

What is the Worldwide Disclosure Facility?

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.

How long do I have after notifying HMRC?

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.

Does having an overseas bank account automatically mean I owe UK tax?

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.

Can I use WDF if HMRC has already written to me about overseas assets?

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.

Can HMRC go back 12 years for offshore income?

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.

Can HMRC go back 20 years?

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.

Does WDF protect me from criminal prosecution?

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.

What if I paid tax on the income overseas?

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.