HMRC voluntary disclosure: putting past tax right
A voluntary disclosure is when you tell HMRC about income or gains you should have declared in earlier years, before HMRC contacts you. HMRC says penalties will usually be lower if you come forward yourself. IB&Co Accountants helps you work out what is owed, choose the right disclosure route and submit a complete disclosure.
When should I make a voluntary disclosure?
When you realise that tax has been underpaid in a previous year and it cannot simply be corrected by amending a recent return. Common situations include:
- rental income from a flat or room that was never declared
- self-employed or side income, including online selling or social media earnings, not put on a tax return
- income or gains from overseas, such as rent on a family property abroad or foreign bank interest
- a capital gain on selling a second home or shares that was not reported
- not registering for Self Assessment when you should have
HMRC says it does not matter why your tax affairs are wrong, and that it is better to come forward than wait for HMRC to contact you.
Which disclosure route is right for me?
HMRC has different routes depending on what needs disclosing:
- Digital Disclosure Service. The general route for individuals, companies and their agents to disclose undeclared UK or offshore income or gains from previous years.
- Let Property Campaign. For individual landlords who owe tax on letting residential property in the UK or abroad. It is not for non-residential property such as a shop, garage or lock-up.
- Worldwide Disclosure Facility. For anyone disclosing a UK tax liability that relates wholly or partly to an offshore issue.
- Contractual Disclosure Facility (COP9). For disclosures where deliberate behaviour caused a loss of tax. HMRC says that if you enter the contract and make a complete and accurate disclosure of all your deliberate behaviour, it will not open a criminal investigation into what you disclose.
VAT errors cannot be disclosed through the Digital Disclosure Service; they are corrected on a VAT Return or in writing on form VAT 652, depending on the conditions.
How does the disclosure process work?
The main stages are:
- Notify. You, or we as your agent, tell HMRC you intend to make a disclosure. HMRC acknowledges this and issues a disclosure reference and a payment reference.
- Disclose and pay. You then have 90 days from the date of the acknowledgement to make the full disclosure and pay what you owe. If you cannot pay in full by then, you must have agreed a payment arrangement with HMRC by that date.
- Make a formal offer. The disclosure includes an offer to pay what you owe. HMRC’s acceptance of it creates a legally binding contract, and HMRC may ask you for more information before accepting.
Ninety days goes quickly when records have to be found, so we start gathering bank statements, rental records and other evidence straight away.
How many years do I need to disclose?
It depends on why the tax was underpaid:
| Reason | Maximum years |
|---|---|
| You took reasonable care | 4 years |
| You were careless | 6 years |
| You acted deliberately | 20 years |
| You did not register for Self Assessment when you should have | up to 20 years |
Where an inaccuracy involves an offshore matter, the time limit can be up to 12 years. Deciding which category applies is one of the most important judgements in a disclosure, and it needs to be honest and supported by the facts.
What will I have to pay?
A disclosure must include three things: the tax owed, interest and any penalty.
- Interest runs from the date the tax was due until it is paid, calculated daily. HMRC will reject a disclosure as incomplete if the right interest is not included.
- Penalties are a percentage of the extra tax. They can be up to 100% of the tax for UK income or gains and up to 200% for offshore liabilities. Penalties are reduced for telling HMRC yourself and for helping HMRC, but the reduction may be smaller if you took a long time to put things right.
When you make a disclosure, it is you, not an HMRC officer, who must calculate the penalty in the way HMRC’s factsheets describe. Getting this wrong can mean the disclosure is rejected or reopened.
What if HMRC has already written to me?
If HMRC has opened a check or sent a “nudge” letter about rental, overseas or other income, the position changes, and penalty reductions may be lower once HMRC has prompted you. Do not ignore the HMRC letter. Our Tax Investigation Support service deals with HMRC enquiries, COP8 and COP9 cases.
For help filing a late Self Assessment return, see our late tax return service.
How IB&Co helps with voluntary disclosures
- listen to what happened, in confidence, and check whether a disclosure is needed at all
- choose the right route and notify HMRC as your agent, with your permission
- rebuild figures for each year from bank statements and records
- work out tax, interest and penalties year by year
- prepare the disclosure, and help you agree a payment plan if needed
- put your tax affairs on a proper footing for the future, for example with Self Assessment or property tax support
We cannot promise a particular result, and we will not help anyone hide income. What we can do is help you make a disclosure that is accurate, complete and on time.
Frequently asked questions
Telling HMRC about income or gains you should have declared in earlier years, before HMRC contacts you. HMRC says penalties are usually lower if you come forward yourself.
After HMRC acknowledges your notification, you have 90 days to make the disclosure and pay, or agree a payment arrangement.
Up to 4 years if you took reasonable care, 6 years if you were careless and 20 years if the underpayment was deliberate. Offshore matters can go back up to 12 years.
Individual landlords letting residential property can use the Let Property Campaign. You tell HMRC first and then have 90 days to work out and pay what you owe.
No. VAT errors are corrected on a VAT Return or in writing using form VAT 652, depending on the conditions.
HMRC says that in serious cases it may consider a criminal investigation. For deliberate behaviour, HMRC offers the Contractual Disclosure Facility. HMRC says that if you enter the contract and make a complete and accurate disclosure of all your deliberate behaviour, it will not open a criminal investigation into what you disclose. Speak to us before contacting HMRC.
We treat what you tell us in confidence, subject to our legal and professional obligations, including anti-money laundering rules. We will explain your options before anything is sent to HMRC.
Talk to us in confidence
Book a Discovery Call, or if HMRC has already written to you, email hello@ibandco.co.uk with “URGENT: HMRC” in the subject line.
Call 020 7164 0225 or visit us at Level 37, 1 Canada Square, Canary Wharf, London E14 5AA. Open Monday to Friday 9:00 to 18:30 and Saturday 10:30 to 16:30.
Checked on 11 November 2026. This page is general information based on HMRC guidance at that date, and is not advice for your circumstances.
