Over the years there have been several what are usually called disclosure facilities of which the most important recently have been the Lichtenstein Disclosure Facility (LDF), Contractual Disclosure Facility (CDF), and the Worldwide Disclosure Facility (WDF). These are all generous initiatives to encourage taxpayers to regularize their affairs.

The state in the form of HMRC has been criticized in the press for being too generous with widespread immunity from prosecution in return for full cooperation. There are a few good reasons:

Government departments tend to think in annual cash budgets so may not be attracted to protracted expensive trials with uncertain outcomes
Those convicted of tax fraud may not have available assets, or may not be given restitution sentences, an agreed repayment schedule benefits the state
Inquiries are enormously expensive. There are no statistics but in our opinion, HMRC is unlikely to show a surplus of additional tax, interest, and penalties collected over the full cost of an inquiry
A lost sheep’s business may live to employ others generating taxable profits, PAYE, and NI