Ten years on, WDF is not bringing in the anticipated revenue, but over the past two years HMRC has secured over £100m each, and the number of disclosures is up

LONDON, UNITED KINGDOM, August 18, 2026 /EINPresswire.com/ -- Amit Puri, the Managing Director of Pure Tax Investigations examines the Worldwide Disclosure Facility ten years on, for the ACCA. He said the WDF is not bringing in the anticipated revenue.

The WDF initiative provides individuals who have earned income or achieved gains overseas with a streamlined opportunity to bring their UK tax affairs up to date by making a voluntary disclosure through an HMRC portal. Provided the disclosures made online are full and complete, there is no need to engage further with HMRC.

See the ACCA article, "Is HMRC's Worldwide Disclosure Facility working?"

But, despite a recently growing number of disclosures, and more ‘nudging’ on the part of HMRC, the trend of total annual tax receipts has been down. Amit said there was 'more to be done' but HMRC has secured just under £920m from WDF to date, including taxes, statutory late payment interest and penalties. The average tax secured per disclosure figure has not increased over time

The Worldwide Disclosure Facility is an example of where HMRC’s one-to-many / nudge-letters approach has been deployed, which is not as resource intensive as one-to-one enquiries.

Nudge Letters performance
There is a correlation between the number of one-to-many letters sent out by HMRC and the number of WDF disclosures received (see graphic). However, with fewer than 2,000 informal letters being sent out a month, it is low in comparison to the millions in lines of banking accounts data HMRC receives every year.

As an example, the total number of WDF disclosures received in 2018 and 2019 was 16,589, but the number of offshore accounts reported to HMRC in, say, 2017 or 2018 was around three or four million. The data exponentially eclipsed the number of disclosures made and the number of nudge letters HMRC sent out.

Surprisingly, the average tax secured per disclosure figure has not increased over time. This is despite HMRC extending the 12-year tax-assessing rule for offshore matters and offshore transfers. One would expect there to be more tax years included in WDF disclosures.

Annual tax revenues from WDF disclosures have not increased, which seems to correlate with the low numbers of nudge letters sent out. It is unclear whether this is because HMRC is unambitious, incapable of doing more or just drowning under all the banking data.

Some suggest that HMRC has ramped up the number of regular one-to-one enquiries carried out using the bulk offshore financial accounts data, but this does not appear to be the case. It seems apparent that the number of WDF disclosures being made remains directly influenced by the number of nudge letters sent by HMRC.

Those who wait for HMRC to contact them lose the ability to make a wholly voluntary disclosure and are therefore unable to secure the minimum penalties. It is still a good time to review a client’s overseas activities, accounts, wealth etc, and ensure that UK taxes on investment income and gains are correctly calculated and disclosed.

We should secure the best possible outcome for clients, based on robust knowledge about tax assessment time limits, the various offshore penalty regimes that apply and double-taxation relief quirks.

Amit Puri
Pure Tax Investigations
+44 20 3757 5669
info@pure-tax.com
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