No. You cannot make a disclosure under the New Disclosure Opportunity (NDO) if you have not held either an offshore account or asset that has been connected in some way with a loss of UK tax.
However, anyone can make a disclosure to HMRC of unpaid liabilities at any time. The fixed penalty under NDO will not be available but people who make a full and voluntary disclosure can expect a lower penalty than if HMRC raised an enquiry or compliance check without the disclosure.
HMRC have told us:
Wholly 'domestic' disclosures are not within the scope of the NDO, and penalties will be due in line with normal HMRC policy. In practice it is likely to result in a penalty of no more than 10% where customers qualify for the additional 10% abatement for unprompted full disclosures. However, particularly in the more serious cases or where the disclosure was not unprompted, penalties may well be more.
It is particularly important when making a disclosure to obtain specialist professional advice in order to avoid, or at least minimise, the risk of criminal prosecution.
