Worldwide disclosure facility penalty assessments - update

Earlier this year HMRC issued assessments to taxpayers in respect of offshore tax disclosed using the worldwide disclosure facility following the introduction of the requirement to correct (RTC) legislation (F(No 2)A 2017 Sch 18). These rules extended some assessing time limits which ran out on 5 April 2021.

HMRC is now contacting taxpayers and agents to discuss the circumstances that led to offshore income not being declared. Taxpayers are invited to share any mitigating factors that can be considered when assessing a penalty. HMRC will send a letter to taxpayers and agents ahead of calling them.

After that call HMRC will send the taxpayer a letter setting out the penalty that will be charged – assuming one is due. The taxpayer will then have an opportunity to tell HMRC about any further evidence before a penalty assessment is raised 30...