Over the years there have been several what are usually called disclosure facilities of which the most important recently have been the Lichtenstein Disclosure Facility (LDF), Contractual Disclosure Facility (CDF) and the Worldwide Disclosure Facility (WDF). These are all generous initiatives to encourage taxpayers to regularize their affairs.

The state in the form of HMRC has been criticized in the press for being too generous with widespread immunity from prosecution in return for full cooperation. There are a few good reasons:

  • Government departments tend to think in annual cash budgets so may not be attracted to protracted expensive trials with uncertain outcomes
  • Those convicted of tax fraud may not have available assets, or may not be given restitutional sentences, an agreed repayment schedule benefits the state
  • Enquiries are enormously expensive. There are no statistics but in our opinion HMRC is unlikely to show a surplus of additional tax, interest and penalties collected over the full cost of an enquiry
  • A lost sheep’s business may live to employ others generating taxable profits, PAYE and NI


HMRC has taken to promoting these schemes with menaces but it’s a world where honey attracts more than vinegar. The LDF was demonized in the press for being generous but its architects can point to collections exceeding budget by a rumoured 200%. 

It’s a funny one, but the CDF is an area where we’ve been able to deliver massive added value not only psychologically but also in cash terms. Clients have come to us with sleepless nights over what is quite often a small fraud, one that with our experience we know the Revenue will allow into one of the facilities, these days usually the CDF. Where we add the value is around the concept of total disclosure. Clients going into CDF may have made unwise dispositions which HMRC with a little discretion will allow us to unwind. If you’ve made mistakes the CDF could be the best thing that’s ever happened in your financial life.

If you think you might be in trouble please call in confidence. We won’t catastrophize. What you think is a major fraud might easily be dealt with voluntarily using the Digital Disclosure Service.

“Where we add the value is around the concept of total disclosure.”