On 5 September 2016, HMRC launched its digital disclosure service. This allows taxpayers to make voluntary disclosures of underpaid corporation tax (and NICs) provided HMRC has not opened an enquiry into the relevant return.

Although the new disclosure facility is not specifically designed to offer the disclosing taxpayer more favourable terms, the general tax rules that see lesser penalties imposed on taxpayers making full and unprompted disclosure will apply to disclosures made through this new service.

Under the new service, once HMRC have acknowledged the initial taxpayer notification the taxpayer will have 90 days to make the disclosure and pay the tax (or put in place an arrangement to pay the tax).

The disclosure service can be accessed here.