Date posted: 16th Jun 2025
HMRC has launched a new round of “nudge letters” aimed at individuals listed as Persons of Significant Control (PSCs) over UK companies.
If you’re a PSC, this campaign could directly affect you—even if you haven’t received a letter yet.
What Is the HMRC PSC Disclosure Campaign?
In recent months, HMRC have begun contacting individuals who are recorded on the Companies House PSC register but who may not have declared income or gains related to their company involvement.
This campaign forms part of HMRC’s wider strategy of using data analytics and third-party information to identify potential underreporting of tax. By cross-referencing PSC data with tax return records, HMRC is flagging cases where income such as dividends, salaries, director loans or share disposals may not have been correctly reported.
The letters encourage recipients to review and voluntarily correct their tax affairs (if incorrect) through formal disclosure, potentially avoiding more serious consequences later.
Who Is a Person of Significant Control (PSC)?
You are classed as a PSC if you:
- Own more than 25% of shares or voting rights in a UK company;
- Have the right to appoint or remove directors;
- Or otherwise exercise significant influence or control over a company’s operations.
If you’re listed as a PSC and haven’t declared relevant income or gains, HMRC may assume non-compliance.
What Does a Nudge Letter Mean?
These letters are not formal investigations, but they are a strong indication that HMRC has data suggesting something may have been missed.
The goal is to prompt taxpayers to come forward voluntarily, using HMRC’s Digital Disclosure Service or Contractual Disclosure Facility (in more serious cases). Voluntary disclosure can significantly reduce penalties and interest charges.
Importantly, even if you haven’t received a letter, this may only be a matter of time.
What You Should Do Now
If you are—or have ever been—a PSC, we recommend the following steps:
- Review your tax returns from recent years to ensure all company-related income or gains have been correctly reported.
- Check your Companies House filings to confirm your PSC status and any changes in shareholding or control.
- Speak to your Clive Owen LLP contact as soon as possible if you’re unsure about your obligations.
Voluntary disclosure is always better than waiting for an investigation or assessment as this can lower any potential penalties.
We’re Here to Help
We’ve helped many new clients handle voluntary disclosures efficiently and with minimal disruption. If you’ve received a letter—or think you may be affected—don’t delay.
Click here to contact our team.
