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HMRC internal manual

Specialist Investigations Operational Guidance

Case identification: unprompted disclosure cases: general

At the core of HMRC’s compliance strategy is the wish to encourage voluntary compliance.

Currently most voluntary disclosures will either be handled under the Contractual Disclosure facility (CDF) or through one of the publicised offshore disclosure facilities, such as the Liechtenstein Disclosure Facility (LDF). It will be rare to encounter a genuinely unprompted disclosure which does not fulfil the criteria for either CDF or an offshore disclosure facility. It is extremely important to ensure that no disclosures which ought to fall within CDF are accepted locally. Taxpayers who wish to enter CDF should complete form CDF1.

Whilst unprompted disclosure is to be encouraged and sought, HMRC must retain the freedom to deal with each case in the right way. Inappropriate HMRC action in a substantial unprompted disclosure case can compromise future action.

For any disclosures relating to avoidance you should ensure that an ERT form is completed.