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Is HMRC’s guidance on voluntary disclosure creating more problems than it solves?

14 June 2022 / Andrew Park
Issue: 4844 / Categories: Comment & Analysis
Into the lion’s mouth

Key points

  • HMRC has made it easy for taxpayers to self-report online for tax fraud by requesting to go into the contractual disclosure facility (CDF).
  • Although professional advice is vital HMRC’s warnings to that effect are limited and perfunctory.
  • HMRC’s electronic architecture must recognise there are boundaries where direct taxpayer access is not appropriate.

Largely unnoticed in March HMRC issued revised guidance to taxpayers on how to make voluntary disclosures of anything they might have omitted. Somewhat surprisingly HMRC is now signposting the means whereby the public can contact HMRC directly – rather than necessarily through professional advisers – to self-report for ‘deliberate behaviour’ ie for tax fraud. The guidance is found at

HMRC has actively sought to make it easier for taxpayers to contact them directly to put general matters right for several years now and for more than five years ...

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