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Let Property Campaign Voluntary Disclosure: Why It Makes Sense

Published By Susan Basnet
Published Date: June 11, 2025

( Last Updated: July 2, 2025 )

If you're a landlord and not reported your rental income, it’s crucial to act now. HMRC is ramping up its enforcement efforts, backed by significant investment in data analysis and compliance teams. The Spring Budget pledged an additional £100 million to hire 500 new HMRC compliance officers, along with £79 million for third-party debt collectors over the next five years. These funds build on the 1,800 debt management roles announced in the Autumn Budget.

However, landlords who come forward for the Let Property Campaign voluntary disclosure can benefit from lower penalties and avoid the stress of a full HMRC investigation. To learn more about this incentive from HMRC, explore our complete guide.

Delays can be costly. The longer you wait, the more you risk—in the form of interest, penalties, or even prosecution. Voluntary disclosure, especially before HMRC contacts you, can save you thousands and give you peace of mind.

Whether your omission was accidental or intentional, support is available. If you're unsure how to begin, speak to a tax specialist with experience in LPC disclosures.

Let Property Campaign Voluntary Disclosure Means Lower Penalties

To re-iterate, the best time to come forward regarding your unpaid taxes is now, i.e. before HMRC contacts you. By making a Let Property Campaign voluntary disclosure, you may significantly pay lower penalties. Once HMRC initiates an enquiry, the penalties increase.

If the taxpayer has never filed any tax returns, and therefore not notified HMRC of their liability to tax, the following penalties will apply.

Type of Behaviour

Unprompted Disclosure

Prompted Disclosure

Non-deliberate- disclosure within 12 months

0% to 30%

10% to 30%

Non-deliberate-disclosure 12 months or more late

10% to 30%

20% to 30%

Deliberate

20% to 70%

35% to 70%

Deliberate and concealed

30% to 100%

50% to 100%

Understanding the definition of behaviour

  • Non-Deliberate: Applies when the omission was due to ignorance or circumstances rather than intent.
  • Deliberate (not concealed): Applies when the landlord knowingly failed to report rental income but did not take further steps to hide it.
  • Deliberate and Concealed: Applies when the landlord both failed to disclose and actively tried to conceal the income.

On the other hand, when the taxpayer has filed their tax return but failed to declare the income from the property, the following penalties apply:

Type of Behaviour

Unprompted Disclosure

Prompted Disclosure

Reasonable Care

No Penalty

No Penalty

Careless

0% to 30%

15% to 30%

Deliberate

20% to 70%

35% to 70%

Deliberate and concealed

30% to 100%

50% to 100%

Reasonable Care

HMRC does not define reasonable care precisely—it depends on each case. In general, landlords are expected to seek appropriate advice if they are unfamiliar with tax rules and ensure they file accurate returns.

Careless

A failure to take reasonable steps to ensure the tax return is correct. This might include failing to keep proper records or overlooking known tax obligations.

Deliberate

If the landlord, despite being aware of inaccuracies in return, files it to HMRC, then HMRC charges a penalty for his intentional error. Examples of this could be understating business income, or overstating income in return.

Deliberate and Concealed

Deliberate and concealed is the case where the landlord not only files inaccurate returns but also actively takes steps to conceal the inaccuracies from HMRC. Examples of this could be supplying HMRC with a fake invoice to cover non-occurred repairs.

Quality of Disclosure: A Key Factor in Penalty Reduction

Penalties may be reduced based on how fully and honestly a landlord engages with HMRC. A high-quality disclosure includes:

  • Telling HMRC about the issue (30%)
  • Helping HMRC understand it (40%)
  • Giving Access to Records (30%)

Example: LPC Voluntary Disclosure vs. Prompted Disclosure (Failure to Notify)

Ben owns eight rental properties that have been generating income since the 2016/17 tax year. He never submitted tax returns for this income, despite earning £45,000 in annual rental income. After allowable deductions and mortgage interest, his annual profits were around £33,000, rising each year. His employment income (fully taxed via PAYE) started at £80,000 and increased by 3% annually.

Example Voluntary Disclosure vs. Prompted Disclosure (Failure to Notify) - Let Property Campaign

His unpaid tax is calculated as follows:

Particulars / Tax Years

2016/17

2017/18

2018/19

2019/20

2020/21

2021/22

2022/23

2023/24

Employment income

80,000

82,400

84,872

87,418

90,041

92,742

95,524

98,390

Profit from UK land

33,000

33,990

35,010

36,060

37,142

38,256

39,404

40,586

Total income

113,000

116,390

119,882

123,478

127,182

130,998

134,928

138,976

Personal Allowance

(4,500)

(3,305)

(1,909)

(761)

-

-

-

-

Mortgage Interests

8,000

8,240

8,487

8,742

9,004

9,274

9,552

9,839

Taxable income

100,500

106,905

113,729

120,532

127,182

130,998

134,928

138,976

Tax Liability

33,800

36,062

38,592

40,713

43,373

44,859

46,431

48,742

Less: Mortgage interest relief

0

(412)

(849)

(1,311)

(1,801)

(1,855)

(1,910)

(1,968)

Tax Payable

33,800

35,650

37,743

39,401

41,572

43,004

44,512

46,774

Less: Deducted at source (PAYE)

(21,200)

(21,660)

(22,709)

(22,467)

(23,516)

(24,529)

(25,642)

(26,788)

Unpaid tax

12,600

13,990

15,034

16,934

18,056

18,476

18,879

19,986

The total unpaid tax up until 2022/23 is £113,969.

Assuming non-deliberate behaviour and full cooperation, the penalty rates will be calculated as follows:

Type of Disclosure

Voluntary

Prompted

Type of Behaviour

Non-Deliberate

Non-Deliberate

Penalty Range:

Minimum Penalty
Maximum Penalty

10%
30%

20%
30%

Difference

20%

10%

Reduction of quality of disclosure
(Helping 40%+Telling-30%+ Access to records-30%, total =100%),
Reduction= 100%*difference%

20%

10%

Final Penalty Rate (Maximum – Reduced)

10%

20%

Try out our exclusive LPC Penalty calculator. Stay ahead of the competition and know the applicable penalty amount in your Let property campaign.

Based on the above rates the penalty and interests will be as follows:

Nature of Disclosure

Unpaid Tax (£)

Applicable Rate (£)

Penalty (£)

Interests (£)

Total

Voluntary Disclosure

113,969

10%

11,397

30,344

155,710

Prompted Disclosure

113,969

20%

22,794

30,344

167,107

The interests have been calculated with HMRC’s interest calculator.

In the example above, a voluntary disclosure results in a total cost of £155,710, whereas a prompted disclosure pushes that figure up to £167,107—a difference of £11,397.

In our experience, HMRC may not accept LPC disclosures for the most recent tax year. Therefore, taxpayers making LPC for 2023/24 may receive a notice from HMRC requesting that they file the return instead. Should they do so, there would be penalties for late filing and late payment, along with the interests for late payment.

If a 2023/24 tax return is filed six months late, the following penalties may apply:

Late Filing Penalties

  • Initial penalty: £100 (charged as soon as the return is late)
  • Daily penalties: £10 per day for up to 90 days, totaling £900
  • Six-month penalty: the higher of £300 or 5% of the unpaid tax liability (£999.30, as 5% of £19,986)

Total Late Filing Penalties:

£100 + £900 + £999.30 : £1,990.30

Late Payment Penalty:

  • 5% of the unpaid tax liability, which is £999.30
  • 5% of the unpaid tax liability, which is £999.30

Late payment interests: £771

Total Estimated Penalties for 2023/24: £4,759.90


Example: Voluntary Disclosure vs. Prompted Disclosure (Inaccurate Returns)

Ms Kim is a self-employed consultant who has been successfully running her business for several years. In the 2018/19 tax year, her trading profits were £130,000. Since then, her business has grown steadily at a rate of 5% per year.

In addition to her consultancy work, Ms Kim owns two rental properties which generated £28,000 in gross rental income in 2018/19. After deducting £7,000 of allowable expenses, she earned a net rental profit of £21,000 that year. However, she failed to include this rental income in her 2018/19 Self-Assessment tax return—and continued to omit it in subsequent years. The property was purchased on cash so there is no mortgage on the property. However, the rental income and other expenditures have increased by 7% each year.

As such, her tax liability is calculated as follows:

Particulars / Tax Years

2018/19

2019/20

2020/21

2021/22

2022/23

2023/24

Trading Income

130,000

136,500

143,325

150,491

158,016

165,917

Profit from UK land

21,000

22,470

24,043

25,726

27,527

29,454

Total income

151,000

158,970

167,368

176,217

185,543

195,370

Personal Allowance

0

0

-

-

--

-

Taxable income

151,000

158,970

167,368

176,217

185,543

195,370

Tax Liability

53,550

56,537

69,868

64,258

68,454

72,877

Less: Tax Paid on Trading Profit

45,100

47,700

50,430

53,321

56,707

60,262

Unpaid tax

8,450

8,837

19,438

10,937

11,747

12,614

The total unpaid tax liability up to and including the 2022/23 tax year is £59,409. Penalties for these earlier years are calculated based on the nature of the disclosure and the taxpayer's behaviour, as detailed below.

For the 2023/24 tax year, a tax return has already been submitted. As a result, any undeclared income must be corrected by amending the filed return. The amendment window remains open until 31 January 2026, allowing time to rectify the inaccuracy without incurring additional penalties, provided the correction is made within this period.

However, since the payment deadline was 31 January 2025, late payment penalties and interest will still apply. For simplicity, we have excluded payments on account from this calculation.

The penalty rates will be calculated as follows:

Penalty Rate Assessment

Header
Header

Nature of Disclosure

Voluntary

Prompted

Type of behaviour

Deliberate

Deliberate

Penalty Range:

Minimum Penalty
Maximum Penalty

20%
70%

35%
70%

Difference

50%

35%

Reduction of quality of disclosure
(Helping 40%+Telling-30%+ Access to records-30%, total =100%), Reduction= 100%*difference%

50%

35%

Final Penalty Rate

20%

35%

Based on the above rates the penalty and interests will be as follows:

Nature of Disclosure

Unpaid Tax (£)

Applicable Rate (£)

Penalty (£)

Interests (£)

Total

Voluntary Disclosure

59,409

20%

11,882

14,152

85,443

Prompted Disclosure

59,409

35%

20,793

14,152

94,354

In this case, coming forward voluntarily leads to a total cost of £85,443, compared to £94,354 if HMRC contacts you first—a difference of £8,911.

As stated earlier, the penalties for 2023/24 tax year will be calculated differently. If the return is paid now, i.e. date of the article publishing date,

Late Payment Penalty:

5% of £12,614 = £631

Interest on late payment = £355

The total tax, interest and penalty for 2023/24 tax year is £13,600.

What happens if you cannot pay the full amount?

HMRC expects you to pay what you owe when you make your disclosure.

If you cannot pay the full amount, you’ll need to let HMRC know as soon as possible and before you send in your disclosure. To do this, you should contact the Let Property Campaign Helpline.

When you phone, HMRC will want to talk to you about your current financial position so they can tell you what they think you should pay and when. To help HMRC decide, you’ll need to tell them:

  • your disclosure reference number
  • how and when you intend to pay HMRC what you owe
  • what your current weekly or monthly income and outgoings are
  • what you own, including your home, other property and land, vehicles, investments, money in the bank
  • what you owe, including mortgages, loans, credit cards

If you cannot pay the full amount, do not submit your disclosure or payment until you have spoken to HMRC.

Conclusion

The message is clear: if you have undeclared rental income, now is the time to act. HMRC is actively increasing its enforcement efforts, and delays only make matters worse—through rising penalties, interest charges, and the stress of potential investigation.

The Let Property Campaign voluntary disclosure offers a unique opportunity to come forward and benefit from significantly lower penalties. Whether your omission was accidental or deliberate, early disclosure puts you in control and can save you thousands of pounds.

Want to know more about how to make a voluntary disclosure through LPC? 

Contact us today for efficient and
hassle-free assistance.

Susan Basnet
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