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.

Changing landscape


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

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

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

16 March: 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.

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

  • Understanding your obligations and creating the right tools for compliance.
  • Ensuring that your people receive the right e-learning and training.
  • 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.

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.

Key contacts

Tom Rowbotham

Tom Rowbotham


Tom is a member of the Tax Disclosure and Transparency team within the UK practice. He is jointly responsible for the firm's strategy in this area and is seen as an expert both within and outside the ... More

Nigel Barker

Nigel Barker


Nigel has recently been appointed as the co-leader of our Private Client Tax Disclosure and Transparency team with a particular focus on information exchange and the handling of tax disclosure cases. ... More

Jo Huxtable

Jo Huxtable


Jo is based in Guernsey and is the leader of Deloitte’s Channel Islands tax practice. Originally from London where she trained with Arthur Andersen, she moved to Guernsey in 2003. Since then, she has ... More

Annis Lampard

Annis Lampard


Annis is a member of the Tax Disclosure and Transparency team within the UK firm. Before joining Deloitte, Annis worked within HMRC. Annis has worked with high net worth individuals, with large corpor... More