On 31 December 2015, all HMRC offshore facilities closed. Up to that date, HMRC gave incentives to encourage people to come forward and clear up their tax affairs. That’s no longer the case, but before automatic exchange and new sanctions come into force, the Worldwide Disclosure Facility (“WDF”) will be the final chance to come forward before HMRC uses Common Reporting Standard data and a tougher approach to offshore non-compliance. The WDF facility opened on 5 September 2016.

The WDF guidance has recently been updated to advise that from 17 June, the current 90-day window will be extended in certain circumstances but taxpayers must agree the extension with HMRC in advance and register for a disclosure reference number.

In exceptional circumstances, if the taxpayers affairs are particularly complex, the taxpayer can apply for up to 90 additional days from notification in which to make their disclosure, giving up to 180 days in total. If you wish to check eligibility for this additional time contact HMRC on +44 300 322 7012.

After 30 September 2018, new sanctions under Requirement to Correct will be introduced that reflect HMRC’s toughening approach. You can still make a disclosure after that date but those new terms will not be as good as those currently available.