After much speculation, ‘Son of LDF’ has now been launched by HMRC in order to give individuals and entities the opportunity to correct their UK tax position if they have previously made errors or omissions in declaring overseas income and gains.

The new Worldwide Disclosure Facility (WDF), launched on 5 September 2016, replaces the Liechtenstein Disclosure Facility and 3 British Crown Dependencies Facility that came to an end on 31 December 2015.

The facility is expected to end on 30 September 2018, though as seen from the previous disclosures, HMRC have both extended and then shortened such dates.

HMRC are also looking to introduce legislation in April 2017 to require any person who has undeclared UK tax liabilities from overseas interests to make a disclosure to HMRC of this by 30 September 2018.

Whilst coming forward voluntarily will not grant immunity from prosecution, it will certainly lessen the chance of this happening. It is expected that penalties will start at 30%, rising depending on the person’s behaviour and jurisdiction the funds were held in up to 300% if HMRC receive no disclosure or cooperation.

The WDF runs alongside HMRC other current campaigns which are still open for taxpayers to come forward and make a voluntary disclosure to bring their tax affairs up to date because of previous omissions or errors. The campaigns still in operation are :-

• Let Property Campaign
• Second Income Campaign
• Credit Card Sales Campaign

A general disclosure facility is also available for any person requiring to make a disclosure of income that is not specifically covered by the above campaigns.

For assistance in making a disclosure, or if you have any queries concerning whether you are required to make a disclosure then please contact Chris Watts or Karen Bowen.

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