Is HMRC’s guidance on voluntary disclosure creating more problems than it solves?

Largely unnoticed in March HMRC issued revised guidance to taxpayers on how to make voluntary disclosures of anything they might have omitted. Somewhat surprisingly HMRC is now signposting the means whereby the public can contact HMRC directly – rather than necessarily through professional advisers – to self-report for ‘deliberate behaviour’ ie for tax fraud. The guidance is found at tinyurl.com/hmrcvoldiscl.

HMRC has actively sought to make it easier for taxpayers to contact them directly to put general matters right for several years now and for more than five years has offered the facility to do it online through its digital disclosure service portal. Many taxpayers have taken that opportunity albeit on the whole they have wisely instructed tax advisers to do so on their behalf.

Taxpayers should always seek professional advice even on a minor disclosure except perhaps where:

• they...