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
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.

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 | 10% | 20% |
Difference | 20% | 10% |
Reduction of quality of disclosure | 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 | 20% | 35% |
Difference | 50% | 35% |
Reduction of quality of disclosure | 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:
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.
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