Voluntary disclosures

HMRC is better informed than ever before, and holds in excess of one billion pieces of information within a sophisticated data interrogation system called ‘Connect’.

This is fed from 28 data sources from organisations such as Companies House, Land Registry, Benefits Agency, Experian, eBay plus onshore and offshore banks. In addition, HMRC has negotiated agreements with a number of previously impenetrable overseas authorities, which includes sharing information about taxpayers, their bank accounts and the income, dividends and gains received. Examples are Liechtenstein, Switzerland, Isle of Man, Jersey and Guernsey. In addition, from 2017, 97 countries have committed to automatically exchange taxpayer information under the Common Reporting Standard (“CRS”). HMRC will receive information about overseas accounts, insurance products and other investments, including those held by UK resident taxpayers through overseas structures. In addition to the CRS, HMRC will also be receiving data on corporates and trusts under a central register of beneficial ownership.

All this collated onshore and offshore information is analysed by Connect to identify possible errors or omissions in a taxpayer’s affairs. The number of investigations commenced by HMRC that are generated by leads from Connect has risen each year and is now considered to be in excess of 90% of cases. One must now reasonably assume that any investigation has originated from an adverse risk report and that you have not been randomly selected.

If HMRC successfully challenges the accuracy of your tax affairs, any errors, omissions or inaccuracies will lead to financial penalties being levied against you. HMRC will seek to apply tough penalties, up to 300% of the tax due for offshore issues, to those who do not voluntarily approach HMRC. In more serious cases, it could lead to criminal investigation and, potentially, criminal prosecution.

A voluntary disclosure to HMRC is the best way of protecting yourself from punitive action by HMRC. If you have undisclosed income, gains, assets or investments here in the UK or overseas, then you need protection.

How can we help?

Great care needs to be taken at the outset in deciding how best to approach HMRC to make a voluntary disclosure and whether there are any formal disclosure facilities available to you.

We have extensive experience having assisted numerous clients in making a voluntary disclosure to HMRC across the whole spectrum of taxation. Our team have made disclosures on behalf of trusts and groups of companies with complex affairs, high-net-worth individuals with onshore/offshore tax aspects, as well as modest cases where a simple mistake has arisen.

From the initial disclosure, through to negotiating final settlement and payment terms, we will control and manage your voluntary disclosure to get you through the process quickly and effectively and will keep you fully informed of progress throughout. We will reduce the extent of HMRC’s potential enquiry, significantly diminish the potential financial penalties that could be charged and minimise the chance of HMRC publishing details about you on its ‘Tax Defaulters’ website.

Our involvement has prevented our clients from being criminally investigated or, worse still, prosecuted. For any client who accepts they deliberately and falsely understated their taxable income, we attempt to secure them immunity from prosecution in return for making a full disclosure of all irregularities.

Request a callback or meeting

If you'd like us to give you a call, fill in your details below and we'll email to arrange a good time to speak to our Head of Tax investigations team, Mark Taylor. All communications are in the strictest confidence.

If you'd prefer to speak to our team directly, please call +44 (0)20 7710 3389.

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