Automatic Exchange of Information for Landlords: CRS, FATCA, DAC7-Equivalent Platform Reporting, the FA 2017 Sch 18 FTC Penalty Escalator, and the Worldwide Disclosure Facility Correction Route

The most important practical fact about Automatic Exchange of Information (AEOI) is that the data flows whether or not the landlord files anything. A UK landlord living in Dubai with a UK buy-to-let does not need to do anything for the UK bank account where rents land to be reported annually to the UAE tax authority under the OECD Common Reporting Standard (CRS); the UK bank applies its due-diligence obligations under SI 2015/878 and reports automatically. The reverse leg, the UAE bank reporting back to HMRC, runs on the same automatic cycle. HMRC's Connect data warehouse cross-matches both flows against UK Land Registry records, Companies House filings, NRL scheme withholding receipts, NRCGT 60-day returns and self-assessment filings, and surfaces discrepancies for human review by an HMRC officer.

That architecture changes the practical calculus for landlords with any offshore element to their position. The "I am offshore so HMRC will not notice" mental model is dead. The "I keep my UK rents in a UK bank account but I live overseas, so my home country does not see it" model is dead. The "I let the flat on Airbnb but only some of the bookings show up" model is dead from 2024 onwards because of the DAC7-equivalent platform reporting under SI 2023/817. The "I hold the property through an offshore company so it is invisible" model has been dead since AEOI, ATED, RoE and Land Registry beneficial-ownership disclosure layered up over the last decade. None of these are aggressive HMRC enforcement; they are statutory information flows that operate by default.

This page walks four things. First, the AEOI information-flow architecture itself: CRS multilaterally, FATCA on the US bilateral leg, the DAC2 EU legacy plus the DAC7-equivalent platform reporting and the Mandatory Disclosure Rules, and how all of this lands in HMRC Connect (Example 1). Second, the four landlord-specific exposure maps: the expat retaining a UK BTL (Example 2), the non-resident with offshore banking (Example 3), the UK landlord with overseas property income, and the Airbnb or platform-let host (Example 4). Third, the penalty escalator architecture for any historical undeclared offshore matters: FA 2017 Schedule 18 Failure to Correct (200 per cent of offshore potential lost revenue with a 100 per cent disclosure floor), FA 2015 Schedule 21 category 2 and category 3 territorial uplift (1.5 times and 2 times standard FA 2007 Schedule 24 percentages), and the underlying inaccuracy regime. Fourth, the Worldwide Disclosure Facility (WDF) correction route via HMRC's Digital Disclosure Service. The triple-reporting overlay for UK-resident US-citizen landlords is covered in Example 5.

The AEOI information-flow map for a typical expat landlord

Take a UK national who has relocated to Dubai keeping a UK buy-to-let portfolio. The data flows as follows.

1. UK rent collected by letting agent. £30,000 gross rent paid by tenant to letting agent on UK BTL.
2. NRL scheme withholding by agent. The Non-Resident Landlord scheme under FA 1995 Schedule 23 obliges the letting agent (or tenant paying rent directly) to withhold 20 per cent basic-rate income tax (£6,000 on £30,000) unless the landlord holds NRL1 approval to receive rent gross. Net rent paid to the landlord is £24,000 (or £30,000 with NRL1 approval, in which case self-assessment carries the income tax liability).
3. Net rent transferred to landlord's UK bank account. Standard practice: the landlord retains a UK bank account to receive rents.
4. UK bank's AEOI reporting under SI 2015/878 and CRS. The UK bank applies CRS due diligence under Regulation 3, identifies the account holder as tax-resident in the UAE, and reports annually to HMRC under Regulation 6: account holder name, UAE tax identification number, account balance at year-end, gross interest credited during the year.
5. HMRC reports onward to the UAE tax authority under MCAA. The UK bank's account data flows from HMRC to the UAE Federal Tax Authority under the reciprocal CRS exchange via the OECD Multilateral Competent Authority Agreement. The UAE tax authority sees the landlord's UK bank balance and activity.
6. Reverse leg: the landlord's UAE bank reports to HMRC. Under the UAE's CRS implementation, the UAE bank reports the landlord's UAE account holdings to HMRC because the landlord may have UK tax-residence flags or because the landlord is reportable from the UK perspective on a continuing connection basis. HMRC sees the UAE balance and activity.
7. HMRC Connect cross-match. Connect aggregates the inbound AEOI data from the UAE, the NRL scheme withholding receipts filed by the UK letting agent, any self-assessment filings, NRCGT 60-day returns on any disposals, and Land Registry records of UK property ownership.
8. Compliance letter triggered if discrepancy. Where AEOI-reported account activity exceeds the declared income on self-assessment, or where NRL withholding receipts indicate ongoing UK rental income without matching SA filings, HMRC issues a compliance letter (an OTM letter, an informal enquiry, or a formal enquiry under TMA 1970 s.29).

The three AEOI strands and the platform-reporting layer

CRS (Common Reporting Standard). The OECD multilateral standard for automatic exchange of financial-account information in tax matters, published in 2014 and revised in 2023. Around 110 jurisdictions are participating, including all major financial centres in Europe, most Caribbean and Channel Islands offshore centres, Singapore, Hong Kong, the UAE, Australia, Canada, and almost every EU and OECD jurisdiction. UK implementation is through the International Tax Compliance Regulations 2015 (SI 2015/878). Reportable data is financial-account level: account holder name, address, tax-residence jurisdiction, TIN, account number, year-end balance, and the year's gross interest, dividends and proceeds from sale or redemption of financial assets. The US is not a CRS participant (it operates FATCA bilaterally instead), and a handful of small jurisdictions (Vatican, Tuvalu, Marshall Islands and so on) remain non-participants.

FATCA (Foreign Account Tax Compliance Act). The US bilateral regime under which foreign financial institutions report US-person accounts to the IRS via the foreign jurisdiction's FATCA Intergovernmental Agreement (IGA). For UK-resident US citizens, FATCA captures their UK accounts. For UK landlords with US bank accounts (typically a US investment property), FATCA captures those US accounts. The UK-US FATCA IGA is a Model 1A reciprocal IGA: UK banks report US-person accounts to HMRC, who passes the data to the IRS, and US banks report UK-person accounts to the IRS for onward sharing to HMRC. UK implementation of FATCA sits alongside CRS within SI 2015/878.

DAC2 (EU legacy) and the post-Brexit MCAA architecture. Directive 2014/107/EU amended the original EU Directive on Administrative Cooperation to incorporate CRS reporting between EU Member States. The UK applied DAC2 as an EU Member State until Brexit. Post-Brexit, the UK no longer participates in DAC as a Member State, but the underlying CRS exchange between the UK and all EU CRS participants continues through the OECD MCAA. The directive-versus-MCAA distinction is technical; the operational reality of UK-EU AEOI continues unchanged. DAC6 (Directive 2018/822/EU on mandatory disclosure of cross-border arrangements) was rolled back post-Brexit in the UK and has been replaced by the Mandatory Disclosure Rules (MDR) under SI 2023/38, implementing the OECD Model Rules on disclosable arrangements.

DAC7-equivalent platform reporting (SI 2023/817). The Platform Operators (Due Diligence and Reporting Requirements) Regulations 2023 implement the OECD Model Rules on digital platform reporting in UK law from 1 January 2024. Digital platform operators in scope (Airbnb, Booking.com, Vrbo, similar) must collect and verify host identity, address, TIN and property address, and report annually to HMRC the host's gross consideration, number of let-nights, and VAT registration status. HMRC shares the data with the host's country of residence where the host is resident outside the UK. The first reporting cycle covered the 2024 calendar year, reported in 2025. For UK-resident hosts, this means platform-reported gross rental income lands in HMRC's Connect warehouse and is cross-matched against the host's self-assessment filing.

Example 2: Mr Khoury and the expat-landlord historical non-disclosure scenario

Mr Khoury (Lebanese national; UK-resident 2010 to 2018; relocated to Dubai in 2018 retaining a UK BTL portfolio of three flats acquired between 2012 and 2017). Mr Khoury's letting agent has been operating NRL withholding properly since 2018 (approximately £12,000 per year withheld at 20 per cent on £60,000 of aggregate gross rents). Mr Khoury never registered NRL1 for gross receipt; never filed a UK self-assessment return since 2018; pooled net rents into a UAE bank account.

AEOI exposure analysis as at 2026. The UK bank account where rents land has been AEOI-reported to the UAE since 2018 (Mr Khoury's UAE tax-resident status); the UAE tax authority has approximately 8 years of UK account data. The UAE bank where rents are pooled has been AEOI-reported to HMRC over the same period because Mr Khoury's continuing UK property ownership and prior UK residence make him reportable from a UK perspective on the bank's CRS analysis. HMRC's Connect cross-match sees the NRL withholding receipts (around £96,000 cumulative across 8 years), zero self-assessment filings, and the AEOI-reported UAE balance growth. The discrepancy is the type that Connect routinely surfaces; an OTM-equivalent compliance letter is likely imminent.

Historical UK tax position. Mr Khoury's UK rental profits after allowable deductions are around £27,000 per year (£35,000 gross less £8,000 of allowable expenses), so cumulatively around £216,000 over the 8 years. Income tax due at the marginal rate (assume the basic-rate band is exhausted post-NRL withholding, so higher-rate 40 per cent applies on the surplus) is around £86,400 on the £216,000. NRL withholding already paid is around £96,000, so on the face of it the NRL withholding broadly covers the income tax liability. The substantive UK tax position is close to neutral; the failure-to-file position under FA 2009 Schedule 55 is the immediate compliance issue.

WDF correction route. Mr Khoury's adviser submits a Worldwide Disclosure Facility disclosure via the Digital Disclosure Service covering 2018/19 through 2025/26. The disclosure documents the NRL scheme compliance throughout, the rental-profit calculations year by year, an acknowledgement of the late filings, any balancing income tax liability paid in full with interest under FA 2009 s.101, and a behaviour grading. The grading is careless (Mr Khoury was unaware of the self-assessment filing obligation despite the NRL scheme operating correctly, which is a recurring pattern for expat landlords). Cat-2 offshore uplift likely applies (UAE currently sits in category 2; verify against the gov.uk schedule at filing). Schedule 24 unprompted disclosure mitigation: careless unprompted 0 per cent floor on the Schedule 24 inaccuracy element. Schedule 55 late-filing penalties are assessed separately. Total Schedule 24 inaccuracy penalty exposure is minimal where the unprompted-disclosure timing has held.

Alternative scenario: HMRC contact precedes disclosure. If an OTM letter arrives before Mr Khoury's adviser registers for WDF, the disclosure shifts from unprompted to prompted. Category 2 prompted careless floor is 15 per cent times 1.5, equal to 22.5 per cent. On £86,400 the Schedule 24 inaccuracy penalty is around £19,440. Schedule 55 late-filing penalties remain separately assessed. The timing of the WDF registration relative to the OTM letter is the single biggest lever on penalty exposure: pre-letter unprompted versus post-letter prompted is a difference of around £19,000 to £20,000 on these numbers.

Example 3: Mrs Olsson and the non-resident landlord with offshore banking

Mrs Olsson (Swedish national; never UK-resident; inherited a £900,000 London flat from a UK uncle in 2017; lets it via letting agent under NRL scheme; NRL withholding applied throughout; net rents remitted by SWIFT to a Swedish bank account, with no UK bank account in Mrs Olsson's name). Mrs Olsson believes she has no UK filing obligation because the agent handles everything.

AEOI exposure analysis. The UK bank used by the letting agent to remit rents is not directly AEOI-relevant for Mrs Olsson because the account is in the agent's name (the firm's client account), not in her name. The agent's CRS due diligence does not identify Mrs Olsson as the underlying client for AEOI purposes (the rent is a flow-through to her). The Swedish bank account on the receiving side reports to HMRC if Mrs Olsson is reportable from a UK perspective, but with no UK tax residence and no UK personal account on file, the Swedish bank's standard CRS due-diligence does not categorise her as UK-reportable. Direct AEOI exposure for Mrs Olsson's rental income stream is low.

UK tax position. The NRL scheme is the operative UK regime. The agent withholds 20 per cent of gross rent and accounts to HMRC. Mrs Olsson can register for NRL1 to receive rent gross and file a UK self-assessment return annually claiming allowable expenses, the personal allowance (if a Swedish-resident individual is entitled, which depends on the UK-Sweden double tax treaty position), and any other reliefs; or she can leave the 20 per cent withholding in place as a final-tax position and file no UK self-assessment return. The latter is broadly compliant if the NRL-withheld amount approximates her actual UK income tax liability. For a higher-rate-band non-resident, the 20 per cent is incomplete and the SA route is required to crystallise any further liability; for a basic-rate-band non-resident with deductible expenses, the 20 per cent may over-collect and the SA route allows a repayment claim.

The bigger AEOI exposure for Mrs Olsson is on disposal. When she sells the flat, the proceeds land in her Swedish bank account; the Swedish bank does its annual CRS reporting; the AEOI inflow to HMRC plus the Land Registry record of the disposal plus any missing NRCGT 60-day return triggers a Connect flag. The 60-day NRCGT discipline is critical. Even where no UK CGT is due (because of base-cost rebasing to 5 April 2015 for residential property held since before that date, or because the disposal results in a loss), the 60-day return is mandatory. Missing the 60-day return creates the discrepancy that surfaces under AEOI.

Example 4: Mr Hayek and the DAC7-equivalent Airbnb host scenario

Mr Hayek (UK-resident individual; lets a London flat on Airbnb generating around £25,000 a year of gross rental income from short-term lets). For the 2024 calendar year (the first DAC7-equivalent reporting cycle), Airbnb reports Mr Hayek's host activity to HMRC under SI 2023/817.

Reported data per SI 2023/817 includes host identity (name, address, TIN), the UK property address, gross consideration (£25,000), number of activities (let-nights count), and VAT registration status (if applicable). HMRC receives the report annually and lands the data in Connect. The Connect cross-match against Mr Hayek's self-assessment filing for 2024/25 surfaces three outcomes. Where his SA shows £25,000 of rental income (matching or exceeding the Airbnb-reported gross): clean match, no flag. Where his SA shows £15,000 (under-declared): discrepancy flagged, OTM letter likely. Where his SA shows no rental income at all: clear non-disclosure flag, formal enquiry under TMA 1970 s.29 likely.

Penalty exposure for the under-declared scenario. Schedule 24 inaccuracy on £10,000 of under-declared income. Behaviour grading is at minimum careless (Mr Hayek should have known Airbnb reports under SI 2023/817; the regulations were widely publicised before the 2024 first reporting cycle). Deliberate not-concealed is possible if Mr Hayek understood the reporting and chose to omit. Income tax on £10,000 at 40 per cent (assume higher-rate band) is £4,000. Schedule 24 careless prompted (HMRC's OTM letter is a prompt) is 15 to 30 per cent of £4,000, around £600 to £1,200. Schedule 24 deliberate-not-concealed prompted is 35 to 70 per cent of £4,000, around £1,400 to £2,800. Where the property has been treated as a Furnished Holiday Let prior to the FHL rules being abolished from April 2025, the historical NIC and FHL-relief positions need separate review.

The practical lesson for Airbnb and platform-let hosts is that under-declaration from the 2024 reporting cycle onwards is detectable as a matter of routine. The platform reports gross; the self-assessment must reconcile. The historical (pre-2024) under-declaration window is treatable via WDF or LPC voluntary disclosure depending on the offshore element. From 2024 onwards the position is "report it accurately on the SA, full stop"; the strategic decision is around how to structure the holding (personal versus company, residential rules versus the abolished FHL regime, capital allowances on furnishings, the rent-a-room scheme where applicable) rather than how much to declare.

Example 5: Mrs Henderson and the UK-resident US-citizen triple-reporting scenario

Mrs Henderson (US citizen; UK-resident since 2010; holds a £1.2m London flat personally as primary residence and an £800,000 London BTL for income). Mrs Henderson faces triple reporting.

UK self-assessment. Mrs Henderson files a UK SA each year declaring her UK BTL rental income, her foreign earnings (her US employer salary), and any worldwide income subject to UK arising-basis taxation. From April 2025 the FIG election regime under ITTOIA 2005 ss.845A to 845J may be available depending on her residence history; the 10-of-prior-10-years non-UK-residence gateway is the operative test. Where Mrs Henderson has been UK-resident continuously since 2010, the FIG gateway fails and she remains on the standard arising basis for foreign income.

US Form 1040 and FBAR. As a US citizen, Mrs Henderson files US tax returns on worldwide income regardless of US residence. She owes US income tax on her UK rental income, UK salary, and UK investment income, subject to the US Foreign Tax Credit for UK tax paid. She also files FBAR (FinCEN Form 114) for any non-US financial account exceeding $10,000 aggregate at any point during the year. The FBAR is a separate filing from Form 1040, filed by 15 April with an automatic extension to 15 October.

AEOI cross-reporting. Her UK bank accounts are FATCA-reported by the UK bank to the IRS via HMRC under the UK-US FATCA IGA. Her US bank accounts are CRS-reported to HMRC under the US-UK reciprocal exchange (limited because the US does not participate in CRS, but the bilateral arrangements under FATCA include reciprocal exchange of certain UK-person account data). Both authorities see the other's data; double-side non-disclosure is operationally impossible.

Compliance triangle. UK-side, ensure UK SA correctly captures worldwide income under the operative basis (arising or FIG) and identify any FA 2017 Schedule 18 FTC exposure for any historical offshore non-compliance. US-side, ensure US 1040 and FBAR correctly capture UK income and accounts; claim the IRS Foreign Tax Credit for UK tax paid to avoid double-taxation. Cross-reporting: confirm both filings are mutually consistent; double-side audit risk is a function of inconsistency, not of the absolute numbers reported.

Penalty exposure for non-compliance. UK Schedule 24 plus any category 2 offshore uplift (the US itself is generally treated as category 1 friendly co-operative, but specific account jurisdictions may be category 2 or 3). US IRS penalties are substantial, including FBAR non-willful penalties up to $10,000 per violation and willful penalties of $100,000 or 50 per cent of the account balance per violation. The IRS Streamlined Procedures are available for non-willful historical non-compliance and provide a defined correction route on the US side.

The FA 2017 Sch 18 FTC penalty escalator

FA 2017 Schedule 18 introduced the Requirement to Correct (RTC) and Failure to Correct (FTC) regime. The RTC was a 17-month window from 6 April 2017 to 30 September 2018 within which chargeable persons could disclose historical offshore non-compliance under softer penalties. The window has closed. The FTC regime applies indefinitely to offshore non-compliance not corrected by 30 September 2018, and is the pricing that bites on any historical undeclared offshore matter discovered now.

FTC base penalty: 200 per cent of the offshore potential lost revenue (PLR). Mitigation floor with full disclosure and full co-operation: 100 per cent of the offshore PLR. The mitigation floor is significantly higher than the Schedule 24 base regime's floors (which can be 0 per cent for unprompted careless inaccuracies on UK-only matters). The FTC regime applies to income tax, capital gains tax, and inheritance tax offshore irregularities. Where the offshore matter is concurrently caught by FA 2015 Schedule 21 category 2 or category 3 uplift, the FTC and Schedule 21 pricing interact (the offshore penalty escalator stacks on standard Schedule 24 percentages, and the FTC base sits as a separate higher-floor regime).

The practical message for landlords with historical undeclared offshore matters older than 30 September 2018 is that the substantive correction route now sits at FTC pricing, not the closed RTC track. Voluntary disclosure under WDF remains available and unlocks the 100 per cent floor (versus the 200 per cent ceiling on assessment without disclosure); the timing relative to any HMRC contact still affects whether the disclosure is treated as unprompted or prompted under the underlying Schedule 24 mitigation matrix.

The FA 2015 Sch 21 category 2 and category 3 uplift

FA 2015 Schedule 21 multiplies the FA 2007 Schedule 24 inaccuracy percentages for offshore matters according to the territory category. Category 1 territories (high-information-exchange standard) attract no uplift: standard Schedule 24 percentages apply (careless 0 to 30 per cent, deliberate not-concealed 20 to 70 per cent, deliberate-and-concealed 30 to 100 per cent). Category 2 territories (moderately co-operative) attract a 1.5 times uplift: careless 0 to 45 per cent, deliberate 30 to 105 per cent, deliberate-and-concealed 45 to 150 per cent. Category 3 territories (non-co-operative) attract a 2 times uplift: careless 0 to 60 per cent, deliberate 40 to 140 per cent, deliberate-and-concealed 60 to 200 per cent. The territory schedule is published by HMRC at gov.uk and updated periodically.

For UK landlord cases the typical offshore jurisdictions are: most EU and OECD jurisdictions in category 1 (low or no uplift); Channel Islands, Isle of Man, Cayman, BVI, Jersey, Guernsey, Singapore, UAE often in category 2 (1.5 times uplift); a small handful of non-co-operative jurisdictions in category 3 (2 times uplift). Verify the current schedule at filing time before quoting category to a client; the schedule can shift as jurisdictions improve their information-exchange standards.

The Worldwide Disclosure Facility correction route

HMRC's Worldwide Disclosure Facility (WDF), launched September 2016 and running indefinitely, is the standard voluntary-disclosure track for any offshore non-compliance. Disclosure is made via HMRC's Digital Disclosure Service (DDS). The standard process is registration with HMRC (filling out the WDF registration form online), a 90-day window to compute the liability, and submission of the disclosure with payment of tax, interest under FA 2009 s.101, and any agreed penalty. Where the disclosure is full and unprompted, the chargeable person unlocks the lowest Schedule 24 mitigation floors and is treated co-operatively under the FTC framework.

The WDF is the right route for any of the four landlord exposure scenarios where historical offshore non-compliance is present. Where the non-compliance is purely UK-source rental with no offshore dimension, the Let Property Campaign (LPC) is the alternative track. Where the matter is purely a missed NRCGT 60-day return on a UK property disposal, an NRCGT-specific correction route via direct HMRC correspondence may suffice. Engage specialist tax advice to scope the disclosure correctly, choose the right track, and structure the registration timing to maximise the unprompted-disclosure mitigation.

HMRC Connect and the cross-match architecture

HMRC Connect is a data warehouse and risk-rating system, in operation since 2010, that aggregates inputs from across HMRC's data estate and from external sources. The AEOI inputs (CRS, FATCA, DAC2 legacy, DAC7-equivalent platform reporting, MDR) feed into Connect alongside Land Registry, Companies House, UK banking records under various PAYE and SA reporting obligations, NRL scheme returns, NRCGT 60-day returns, self-assessment filings, DVLA records, and third-party data from digital platforms. Risk-rating algorithms within Connect surface cases where the inputs disagree (e.g. AEOI shows offshore bank activity but SA shows no foreign income; or Land Registry shows a UK property disposal but no NRCGT return matches the date and address). Surfacing is for human review by an HMRC officer, not autonomous enforcement; the officer decides whether to open an enquiry, send an OTM letter, or take no action.

The practical relevance for landlords is that the discovery vectors for non-compliance are now wide and automated. Compliance discipline (file the SA, register for NRL, file NRCGT within 60 days of completion, disclose historical gaps via WDF) substantively eliminates Connect surfacing risk. Where compliance has slipped, voluntary disclosure before HMRC contact preserves the unprompted-mitigation position.

How this page sits alongside the rest of the NRL and disclosure cluster

For the NRL scheme operational mechanics, see our non-resident landlord scheme complete guide. For NRCGT 60-day reporting, see our non-resident CGT page. For Register of Overseas Entities (the parallel corporate-ownership transparency regime), see our RoE annual update statement page. For inbound and outbound landlord positions, see our leaving the UK permanently page and our arriving in the UK page. For the Let Property Campaign alternative correction track for UK-source rental non-compliance, see our Let Property Campaign page.

Frequently asked questions

The FAQ list above covers what AEOI is and the three strands (FAQ 1), expat-landlord exposure (FAQ 2), CRS reported data (FAQ 3), Airbnb and platform-reporting under SI 2023/817 (FAQ 4), the FA 2017 RTC/FTC regime (FAQ 5), the FA 2015 Sch 21 category 2 and 3 uplift (FAQ 6), the Worldwide Disclosure Facility (FAQ 7), non-resident landlord exposure with offshore banking (FAQ 8), the UK-resident US-citizen triple-reporting overlay (FAQ 9), HMRC's use of AEOI data as discovery information (FAQ 10), the post-Brexit UK-EU AEOI position (FAQ 11), the 8-year historical non-compliance correction route (FAQ 12), HMRC Connect (FAQ 13), and the offshore-company structure (FAQ 14).

Next step

If you are an expat landlord retaining UK property, a non-resident landlord with offshore banking, a UK landlord with overseas property income, a platform-let host, or a UK-resident US-citizen landlord with the triple-reporting overlay, AEOI is operating on your data whether or not you take any action. The defensive posture is compliance discipline (NRL registration, NRL1 where the gross-receipt route works, self-assessment filing, NRCGT 60-day discipline on disposals, FBAR for US citizens) and voluntary disclosure via the Worldwide Disclosure Facility or the Let Property Campaign for any historical gaps. The penalty differential between voluntary disclosure pre-HMRC-contact and assessment post-HMRC-contact is substantial: tens of thousands of pounds on a single chargeable period for an offshore-banking expat landlord, and significantly more under category 2 or category 3 uplift. Contact us via the form below to scope your AEOI exposure and the correction route appropriate to your position.