WDF vs COP9 vs Let Property Campaign: Which HMRC Disclosure Route Is Right for You?

If you need to put your tax affairs right, HMRC has several disclosure routes. Choosing the wrong one can cost you time, money and protection.

This guide compares the Worldwide Disclosure Facility, COP9, the Let Property Campaign and general voluntary disclosure, in plain English.

The four main routes at a glance

The right choice depends on where the income came from and why it was not declared.

When to use the Worldwide Disclosure Facility

The Worldwide Disclosure Facility is the right route when the unpaid tax relates wholly or partly to something overseas, for example:

• Interest on a foreign bank account
• Rent from property abroad
• Gains on overseas property, shares or crypto
• Foreign pensions or dividends

Important: a WDF disclosure must include all previously undisclosed UK tax liabilities, including any UK income, not just the offshore element.

When to use the Let Property Campaign

The Let Property Campaign is for individuals with undeclared rental income from UK residential property.

• It suits landlords with one or several UK lets.
• Landlords who live abroad but let UK property can also use it.
• If you also have undeclared overseas income, the WDF is usually the better single route.

When COP9 may be the safer route

The Contractual Disclosure Facility, under HMRC’s Code of Practice 9, is for people who have deliberately evaded tax.

1. You, or HMRC, start the process.
2. You admit deliberate conduct and make an outline disclosure within 60 days.
3. You then prepare a full disclosure report with an adviser.
4. In return, HMRC agrees not to start a criminal investigation into the conduct disclosed.

The WDF does not give that protection. So if deliberate behaviour may be involved, take advice before notifying anything.

General voluntary disclosure

For UK-only errors that are not rental income, such as missed self-employed income or a forgotten capital gain on UK shares, a general voluntary disclosure through the Digital Disclosure Service is usually used.

It follows a similar pattern: notify, then 90 days to calculate and pay.

How to choose: a simple decision guide

1. Was any of it deliberate? If possibly yes, get advice on COP9 first.
2. Is any of the income or gain from overseas? If yes, use the WDF.
3. Is it only UK residential rental income? If yes, use the Let Property Campaign.
4. Anything else UK-only? Use a general voluntary disclosure.

What all routes have in common

• You calculate the tax, interest and penalty yourself.
• Unprompted disclosures attract lower penalties.
• Accuracy and full cooperation reduce the penalty further.
• Missing deadlines weakens your position.

For more on penalties, read our guide to Worldwide Disclosure Facility penalties.

Common mistakes when choosing a route

• Using the Let Property Campaign when there is overseas income too. The WDF is usually the right single route, so everything is settled together.
• Using the WDF when behaviour was deliberate. This gives no protection from criminal investigation. COP9 should be considered first.
• Disclosing only part of the problem. Every route expects a full disclosure. Leaving something out can undo the benefit of coming forward.
• Notifying before you are ready. The 90-day or 60-day clock starts straight away, so request records first.
• Ignoring HMRC letters. A nudge letter is a chance to act on your own terms. Read our guide to the HMRC letter about income or assets abroad.

Most of these mistakes are avoided with one short conversation before HMRC is contacted.