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The Contractual Disclosure Facility (CDF) – your options

The Contractual Disclosure Facility (CDF) offers you the chance to disclose any loss of tax that has been brought about by your deliberate conduct. Remember this offer expires 60 days after you receive our letter making the offer.

You will make a full disclosure of all your tax irregularities under the terms of the CDF. To comply with your part of the contract you need to complete a valid Outline Disclosure of the deliberate conduct that brought about a loss of tax, a certified statement that you have made a full, complete and accurate disclosure of all tax irregularities together with certified statements of your assets and liabilities, and of all bank accounts and credit cards you have operated.

This is the only way that you can be certain that HMRC will not carry out a criminal investigation into the tax frauds they suspect. In exchange for your full disclosure of all irregularities, HMRC will not pursue a criminal investigation into the conduct you disclose.

To comply with the terms of the contract, you will be admitting that tax has been lost because of your deliberate conduct. This means that HMRC may be able to seek recovery of the tax, interest and associated penalties you may have evaded for as far back as 20 years.

If you enter into a CDF contract HMRC expect you to co-operate fully with them. Full co-operation will ensure that you achieve the greatest possible reductions for any penalty that may be due. More information on our penalty regimes is available on the HMRC website.


For further information of the use of the Contractual Disclosure Facility, please contact us immediately.