HMRC disclosures Facilities
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Worldwide Disclosure Facility (WDF) Advisory
We provide expert assistance to individuals and companies disclosing previously undeclared offshore income or assets to HMRC under the Worldwide Disclosure Facility (WDF).
Our WDF Services Include:
- Initial Assessment & Strategy
Reviewing your tax position to determine whether disclosure under the WDF is required or beneficial. - Voluntary Disclosure Preparation
Preparing and submitting full disclosures to HMRC, including necessary financial calculations and narrative reports. - Legal & Tax Guidance
Ensuring that your disclosure is accurate, complete, and in line with UK tax laws and HMRC expectations—minimising risk of penalties or criminal investigation. - Negotiating with HMRC
Engaging with HMRC on your behalf to ensure a smooth disclosure process and favourable settlement terms. - Risk Mitigation
Helping you regularise your tax affairs and avoid future compliance issues or legal consequences. - Post-Disclosure Support
Advising on long-term tax compliance and offshore asset management strategies after closure of the disclosure.
Voluntary Disclosure Facility (VDF) Advisory
We provide comprehensive assistance for individuals and businesses looking to make a voluntary disclosure to HMRC regarding previously undeclared UK tax liabilities.
Whether your disclosure relates to income, gains, VAT, PAYE, or offshore matters, our team ensures full compliance with HMRC’s disclosure protocols—minimising penalties and safeguarding your position.
Our VDF Services Include:
- Eligibility Assessment
Determining whether the Voluntary Disclosure Facility is appropriate for your situation and advising on the most suitable route (e.g. Digital Disclosure Service, Contractual Disclosure Facility). - Disclosure Preparation
Accurately compiling your financial data, preparing detailed disclosure reports, and calculating tax liabilities and interest owed. - HMRC Submissions
Managing all correspondence with HMRC, including registration for disclosure, submission of reports, and payment arrangements. - Penalty Negotiation
Supporting you in reducing penalties by demonstrating cooperation and taking prompt corrective action. - Criminal Risk Mitigation
Helping you avoid potential prosecution by making a full and unprompted voluntary disclosure. - Post-Disclosure Compliance
Advising on best practices and internal controls to ensure future tax compliance and peace of mind.
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The UK Non-Domicile Regime
The UK’s new non-domicile (non-dom) rules, effective from April 6, 2017, introduced significant changes to the taxation of non-domiciled individuals who have been UK residents for 15 of the past 20 years. Our advisory services help clients understand and navigate these complex regulations to optimise their tax position while ensuring compliance.
New Non-Dom Regime — Effective April 2025
From 6 April 2025, the UK will abolish the current non-domicile regime and replace it with a residence-based system. This change affects how foreign income and gains are taxed for UK residents and is critical for non-domiciled individuals to understand and prepare for.
Key Features of the New Regime:
- Abolition of Non-Dom Status for Tax Purposes
The concept of non-domicile will no longer be relevant for UK tax purposes. Tax treatment will now depend solely on residence, not domicile. - New 4-Year Foreign Income & Gains (FIG) Exemption
Individuals who become UK tax resident after a period of 10 years of non-residence will be eligible for a 4-year exemption on foreign income and gains. These amounts will not be taxed in the UK and can be remitted without a tax charge. - End of Remittance Basis
The remittance basis of taxation (which allowed non-doms to defer or avoid UK tax on foreign income/gains not brought into the UK) will be scrapped entirely. - Transition Rules for Existing Non-Doms
Those currently claiming the remittance basis may benefit from temporary reliefs, including:- Rebasing of foreign assets to April 2019 values for CGT purposes.
- Temporary Repatriation Facility (TRF) – a limited window (2025–2026) during which certain foreign income/gains can be brought to the UK at a reduced 12% tax rate.
- Changes to Inheritance Tax (IHT) Rules
A future consultation is expected on moving IHT from a domicile-based system to a residence-based one. Likely proposals include:- IHT liability on worldwide assets after 10 years of UK residence.
- Continued exposure to UK IHT for 10 years after leaving the UK.
Non-Dom Regime Services Include:
- Status Assessment & Modelling
Evaluating your current and future domicile status and modelling the tax implications over time. - Tax Planning Strategies
Advising on structuring income, assets, and trusts to minimise tax liabilities under the new rules. - Compliance & Disclosure
Assisting with tax returns, disclosures, and communications with HMRC in respect of domicile status and related liabilities. - Inheritance Tax Planning
Providing tailored strategies to address inheritance tax exposure as a deemed domicile.
We help non-domiciled individuals and families navigate the complexities of the new regime, ensuring they are fully compliant while optimising their tax and estate planning.