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Why disclose?


There have been numerous favourable tax amnesties available over the past 10 years which were specifically designed to facilitate the disclosure of historical offshore income and gains. HMRC are therefore taking a much stronger stance against any taxpayers who, in their eyes, have deliberately chosen not to disclose despite several prompts and opportunities.

HMRC have also made it clear that they will not hesitate to prosecute individuals where appropriate.

Making a voluntary disclosure can mitigate many of these potential issues. Taking control of the process allows the taxpayer to provide a full picture to HMRC in one go, rather than responding to HMRC’s queries.

Making an “unprompted” disclosure also has a significant impact on the potential penalties which HMRC can seek to assess.

There are currently several options for making a voluntary disclosure to HMRC. Which one is best for you or your client will be dependant on the particular circumstances. Failure to make a voluntary disclosure may result in HMRC opening a Compliance Check or, in more serious cases, a civil or criminal fraud investigation.

Despite the voluntary nature of making a tax disclosure, it is important to remember that any potentially contentious process with HMRC should be taken seriously. Failure to provide a full and complete disclosure of all relevant liabilities may have significant implications.

Equally, it is important that you or your client do not provide HMRC with information that they are not entitled to, as this could lead to further questions or, potentially, a more detailed investigation. It is important to speak to a specialist, who can ensure that the process is properly managed and that the chosen disclosure route is the best option for you, having in mind your wider affairs and the risk of prosecution.


Hamilton Rose have 30 years of combined experience dealing with HMRC and we have dealt with hundreds of voluntary disclosures over that time, including c.300 via the "Liechtenstein Disclosure Facility". We know what your options are for making a disclosure and will ensure that the chosen disclosure route is the best option for you, having in mind your wider affairs and the risk of prosecution.

Hamilton Rose know how to manage the disclosure process correctly to ensure that HMRC receive the information they require in order to accept a disclosure, that the correct amount of tax is paid and that your best interests and assets are protected. We also know who to approach and how best to negotiate "time to pay" the liability on your behalf, if required.