HMRC has updated its guidance on the worldwide disclosure facility (WDF) used to disclose a UK tax liability that relates wholly or in part to an offshore issue to allow an additional 90 days to make a disclosure
The change is outlined in the section headed ‘complex issues and pre-disclosure agreement’.
This states that when a disclosure is complex, the taxpayer can request 90 additional days from notification in which to make their disclosure, giving up to 180 days in total.
Additionally, so that taxpayers can seek clarification of complex issues before submitting their disclosure, HMRC has updated the non-statutory clearance process.
This includes the introduction of a new clearance route that taxpayers can only use if they have already registered to make a disclosure of offshore liabilities through the digital disclosure service (DDS).
HMRC advises that if after considering the relevant guidance, taxpayers are uncertain of the correct treatment to apply in their disclosure, they use the non-statutory clearance process to seek agreement as to the basis to be used in the disclosure.
Having made an application, they will then be contacted by a HMRC specialist in an attempt to clarify the matter.
Anyone who makes a non-statutory clearance application will have 90 days from the time that their clearance application is finalised to submit their final disclosure.
Guidance Worldwide Disclosure Facility: make a disclosure is here.
Non-statutory clearance service guidance is here.
Report by Pat Sweet
