Tax disclosure and transparency

Maintaining compliance in a transparent world

New, international measures, introduced to counter suspected offshore evasion and money laundering will have significant impact for UK taxpayers, including those who have historically been fully compliant in reporting and meeting their UK tax liabilities.

In particular, non-domiciled individuals have previously had no need to report unremitted non-UK income or gains, but will now need to consider the impact of global automatic exchanges of financial data from mid-2017 onwards. Such taxpayers may therefore wish to review their record keeping methods, to ensure that reporting to HMRC remains complete and correct, and so that any questions raised by global information exchanges can be explained swiftly and accurately.

From September 2017, an unprecedented volume of information on financial assets will be exchanged by tax authorities on a global scale.

In addition, the UK has introduced a publically available Beneficial Ownership Register, with all EU states required to introduce similar registers by June 2017. The register will look through intermediate financial interests to the individuals ultimately involved.

The UK government is at the same time introducing a range of new powers to tackle perceived non-compliance with tax and money laundering regulations, particularly where this relates to offshore matters.

These developments, among others, will transform how information is collected, processed and used by financial institutions and tax authorities. As such, the developments affect all taxpayers, including those who have historically been compliant and who have paid their tax liabilities in full.

During the current transition period, clients are looking to understand and review their affairs from a tax and reputation perspective, in readiness for the new regime. Our specialist team can provide a range of services and these are outlined further down this page. As part of this, our team is involved in Deloitte’s cross-service line team that works on compliance with the new corporate criminal offence for failure to prevent facilitation of tax evasion.

Changing landscape


1st May 2019: UK to force overseas territories to publish beneficial ownership registers.

19 February 2018: HMRC launches consultation into 12 year assessment window for offshore matters

19 February 2018: OECD publishes consultation on residency investment visas as an anti-CRS measure

19 January 2018: HMRC commit to more and more public beneficial ownership registers

11 Dec 2017: OECD publish consultation on mandatory disclosures for offshore structures and CRS avoidance

1 Dec 2017: HMRC publish the results of the requirement to notify offshore structures consultation; debate to continue

30 Nov 2017: European Parliament confirms that they will be investigating the findings of the Paradise Papers

22 Nov 2017: The Chancellor announces that HMRC will consult on extending the offshore assessing window to at least 12 years for all cases

31 October 2017: HMRC update their litigation and settlement strategy

26 October 2017: HMRC attribute to shrinking tax gap to more efficient compliance processing and anti-evasion measures

20 June 2017: Worldwide Disclosure Facility terms updated to extend filing dates for complex disclosures

6 April 2017: A statutory Requirement to Correct UK tax errors from offshore income or assets comes into force today

1 April 2017: New asset-based penalties and tax-geared penalty rates are now in force on tax liabilities due from offshore income and assets

1 April 2017: New rules are now in force giving HMRC greater powers to publish taxpayers’ details following tax enquiries

16 March 2017: HMRC have set 1 April as the commencement date for revised penalties on tax from offshore income and assets, and new rules on publishing taxpayer details

27 Feb 2017: HMRC consultation closes on requirement to notify offshore structures

5 February 2017: 2 months left before HMRC’s Serial Tax Avoiders Regime takes full effect

5 February 2017: 2 months left before the statutory Requirement to Correct comes in

1 January 2017: HMRC have declared that civil sanctions on enablers of offshore tax evasion will have effect from 1 January 2017

5 December 2016: HMRC launch consultation on a new requirement to notify HMRC of offshore structures

November 2016: HMRC confirm sanctions to be applied to enablers of defeated tax avoidance

October 2016: HMRC guidance released on corporate criminal offence to prevent failure of tax evasion facilitation

5 September 2016: HMRC launch their Worldwide Disclosure Facility and the accompanying Digital Disclosure Service

13 June 2016: HMRC release factsheet on the higher penalties which may be charged for Income Tax and Capital Gains Tax when an offshore matter is involved

13 April 2016: Prime Minister David Cameron announces bringing forward civil and criminal penalties for enablers – providers of tax, financial and related services need to review internal procedures to comply with new rules

Understand what tax transparency means for you

Our team of leading experts can help you understand what tax transparency means for you.

If you are an individual we can help you by:

  • Understanding which jurisdictions and tax authorities your information will be exchanged with, and how this relates to the information already provided via accurate and complete returns
  • Understanding your obligations under the public and non-public registers of beneficial control. Note that the UK’s public register includes those in positions of control and influence and not just beneficial ownership
  • Assisting you in making a full and complete disclosure to HMRC, e.g. through the Worldwide Disclosure Facility
  • Assist you in risk and enquiry discussions with HMRC

For companies, family offices and trust companies we can help you by:

  • Understanding your obligations and creating the right tools for compliance
  • Help you identify the right e-learning and training needs for your organisation to understand the changing compliance frameworks
  • Understanding and implementing your legal obligations under beneficial ownership registers
  • Assisting you in making a full and complete disclosure to HMRC, e.g. through the Worldwide Disclosure Facility
  • Assist you in risk and enquiry discussions with HMRC
  • Assist you in Alternative Dispute Resolution and mediations with HMRC

Increasing confidence in your tax affairs

The changing climate and increased powers of tax authorities, as well the volume of data available to them, is creating uncertainty and insecurity for taxpayers who have historically taken their tax obligations seriously.

If you are an individual we can help you by:

  • Providing reviews of existing financial affairs to increase your confidence in your record keeping and tax filings.

If you are a trust company, family office or private company we can help you by:

  • Reviewing, implementing and testing tax reporting systems for Resident Non-UK Domiciled individuals.

Regularising tax affairs

A new statutory obligation from April 2017 means that all taxpayers will have a requirement to correct any errors in their historic tax position on offshore assets and income. From October 2018, tax matters not brought up-to-date will enter the “Failure to Correct” regime with tougher penalties attached.

Alongside this, HMRC’s Worldwide Disclosure Facility opened on 5 September 2016 for taxpayers wishing to make corrections to their UK tax position. Globally, different jurisdictions have their own specific rules for regularising tax matters.

In some cases, even where taxpayers have sought to be compliant with their reporting obligations, a fresh review of matters may reveal that innocent errors have unintentionally been made. If this is the case, then a prompt and full disclosure is recommended to HMRC.

At Deloitte we have a proven track record of preparing disclosures to tax authorities in the UK and overseas, including in dispute resolution and mediation in more complex cases.

Compliance services

With a likely increase in the number of enquiries and the legislative framework providing for increased penalties on under-declared tax in respect of offshore assets, it is important that taxpayers get their tax compliance right.

At Deloitte we have a specialist compliance offering, with robust review processes in place. With our global network we can deal with cross-jurisdictional compliance and ensure that multi-national tax legislative changes are quickly adapted to.

If you are a private company, trust company or family office, we can also help you by:

  • Helping to preparing your organisation for tax digitalisation.
  • Preparing trust accounts and providing trustees with compliance support.
  • Reviewing the reporting of wealth and business interests for UK residents.


Making Tax Digital: an overview of data analytics, tax transparency and how the private wealth world is responding.

Tax Transparency: a beginners’ guide to the key tax transparency changes and their impact

HMRC's information powers: a summary of what information the UK tax authorities can request and responding to HMRC requests

Corporate Criminal Offence for Failure to Prevent Facilitation of Tax Evasion: a guide for business on the new Failure to Prevent Facilitation of Tax Evasion and building a defence

Key contacts

Annis Lampard

Annis Lampard


Annis leads the tax disclosure and transparency team. She previously worked in HMRC’s Fraud Investigations Services team and has 10 years’ experience on a wide range of HMRC enquiries involving both i... More

Jenny Tevlin

Jenny Tevlin

Associate Director

Jenny joined the firm in 2004 and worked in the Corporate Tax department before moving to the TDAT team in 2009. She is a Chartered accountant and Chartered Tax Adviser. Jenny has experience in dealin... More

Michael Pape

Michael Pape

Associate Director

Mike is a member of the Tax Disclosure and Transparency team within the UK firm. Before joining Deloitte, Mike spent 17 years with another ‘Big Four’ practice, the majority of which was spent with the... More