HMRC has amended its guidance to include a provision relevant to “complex cases” where, in “exceptional circumstances”, taxpayers can be given an additional 90 days from notification to make a disclosure. This would increase the total time limit to 180 days. It is critical that taxpayers understand and prepare thoroughly when making a notification under the WDF so as not to be caught out by the restrictive time limit built in to the system.

HMRC’s guidance can be found here.