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Undeclared NRE and FCNR interest on your UK return, and how to put it right

You never put your Indian NRE or FCNR interest on your UK tax return because it was tax-free in India, and now you want to come clean before HMRC raises it first.

You are a UK resident with NRE or FCNR accounts in India. The interest is tax-free in India, so for years it never occurred to you that it belonged on your UK return, and it was left off. Now you have realised the UK taxes your worldwide income, HMRC receives Indian account data automatically, and the gap needs fixing before a nudge letter or an enquiry arrives. The route is HMRC's Worldwide Disclosure Facility, and the part that is genuinely hard, and squarely Indian-side work, is rebuilding an accurate year-by-year history of the interest you earned.
Last reviewed: 30 July 20267 min readReviewed by Preetesh Maloo, CA

The short answer

NRE interest is exempt in India under Section 10(4)(ii) and FCNR interest under Section 10(15)(iv)(fa), so India deducted nothing. But a UK resident taxed on the arising basis owes UK tax on that interest, and because no Indian tax was paid there is no credit to reduce the UK bill. If it was left off past returns, HMRC's Worldwide Disclosure Facility is the way to correct it: you notify through the Digital Disclosure Service, get a reference number, then have 90 days to file the full disclosure and pay. Coming forward voluntarily pulls the penalty down toward its floor; leaving it until HMRC finds the CRS data does the opposite, and for older years the penalty can be severe. Our job is the India side, the reconstructed interest history your UK adviser needs to file the disclosure.

References on this page

  • Section 10(4)(ii): NRE-account interest exempt in India while non-resident
  • Section 10(15)(iv)(fa): FCNR-account interest exempt in India
  • HMRC Worldwide Disclosure Facility: notify via the Digital Disclosure Service, then 90 days to disclose and pay
  • UK arising basis: a UK resident is taxed on worldwide income, so India's exemption gives no UK relief
  • India-UK DTAA, Article 24 (tax-sparing) as a possible, contested mitigant, capped at 15% and about 10 years

Why tax-free-in-India interest still belonged on your UK return

The exemption is Indian, and it stops at the Indian border. NRE-account interest is exempt in India under Section 10(4)(ii) while you are non-resident, and FCNR-account interest under Section 10(15)(iv)(fa), so the bank deducts no tax and nothing shows on an Indian return. That is where the tax-free reputation comes from, and inside India it is correct.

The UK does not recognise it. A UK resident taxed on the arising basis is taxed on worldwide income as it arises, so the NRE and FCNR interest is UK-taxable foreign savings income at your UK rates. And because India levied no tax, there is no foreign tax to credit against the UK charge, so unlike taxed Indian income it brings no relief. One caveat matters for older years: if you were historically a non-domiciled resident using the remittance basis and did not bring the interest into the UK, you may not have owed UK tax on it then. That regime was abolished from 6 April 2025, so for anyone on the arising basis the interest is now plainly UK-taxable and any past gap needs correcting.

What the Worldwide Disclosure Facility is

The Worldwide Disclosure Facility is HMRC's standard route for telling them about a UK tax liability connected to anything offshore, including foreign interest that was left off your returns. It has run since 5 September 2016 and anyone can use it, including a non-UK resident.

It works in two steps. First you notify HMRC through the Digital Disclosure Service, and they issue a disclosure reference number. Then you have 90 days from that acknowledgement to submit the full disclosure, the income year by year with the tax, interest and penalty worked out, and to pay. The reason to use it rather than wait is simple: a disclosure you volunteer is treated far more leniently than a liability HMRC uncovers from the Indian account data it already receives under the Common Reporting Standard.

How far back it goes, and the penalty

How many years are in scope, and how large the penalty is, both turn on behaviour. An innocent oversight reaches back fewer years and carries a smaller, tax-geared penalty; a deliberate and prolonged failure opens the longest assessment window, up to 20 years, and at the extreme can bring criminal exposure.

For older undisclosed years there is a sting worth knowing about. Anyone with undeclared offshore tax that was still uncorrected after the Requirement to Correct deadline of 30 September 2018 falls under the Failure to Correct regime, where the penalty starts at 200% of the tax and reduces toward a 100% floor depending on how good the disclosure is, with a further asset-based penalty of up to 10% where the tax in a year tops 25,000 pounds. So the headline is real for older years, and voluntary disclosure through the facility is exactly what brings the penalty back down. One possible mitigant is the India-UK tax-sparing credit, which can in principle credit the Indian tax that was spared on NRE interest, but it is capped at 15%, limited to about 10 years, and it is genuinely unsettled whether HMRC allows it on interest that was fully exempt, so treat it as an adviser-dependent maybe, not a certainty.

The India side, which is where we come in

The disclosure lives or dies on the numbers, and the numbers are Indian. To file it you need an accurate history of the NRE and FCNR interest you earned, year by year, for however many years are in scope, potentially a long way back. That means going to each Indian bank for the interest certificates and account statements, reconstructing the interest per financial year, and converting it to the relevant UK tax years so your UK adviser can drop it straight into the disclosure.

That reconstruction, from Indian banks, in a form a UK adviser can use, is the India-side work a practising CA does. We compile the interest history, confirm the Indian exemption basis so the position is clearly stated, and hand over a clean pack. We do not file your UK disclosure or deal with HMRC, that is your UK adviser's role. We make sure the Indian figures behind it are complete and right, because an under-stated or patchy history is what turns a clean disclosure into a reopened one.

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What's involved

What the CA actually does

  1. 1

    We rebuild the interest history year by year

    We go to your Indian banks for the NRE and FCNR interest certificates and statements and reconstruct the interest earned each financial year, for as many years back as the disclosure needs.

  2. 2

    We convert it to your UK tax years

    We restate the Indian-year interest onto UK tax years with the exchange basis noted, so your UK adviser can enter it into the disclosure without re-working the figures.

  3. 3

    We confirm the Indian exemption basis

    We document that the NRE interest was exempt under Section 10(4)(ii) and the FCNR interest under Section 10(15)(iv)(fa), so the disclosure states cleanly why no Indian tax was ever paid.

  4. 4

    We flag the tax-sparing question for your adviser

    Where your NRE account is relatively recent, we give your UK adviser the account dates and interest so they can weigh the Article 24 tax-sparing credit, which we do not claim ourselves.

  5. 5

    We stay India-side only

    We do not notify HMRC, file the Worldwide Disclosure, or act as your UK tax agent. We build the Indian interest history the disclosure rests on; the UK filing is your UK adviser's job.

What to have ready

Documents you'll typically need

  • NRE and FCNR interest certificates for each year, if you have them
  • Account statements for the NRE and FCNR accounts
  • The dates each account was opened
  • A list of the Indian banks and account numbers
  • Your PAN and your UK adviser's details

Frequently asked questions

Common questions

Undeclared NRE or FCNR interest to disclose in the UK?

Tell us your accounts and how far back it goes. A practising CA will rebuild the Indian interest history your UK adviser needs. Free call, no obligation.

No card, no obligation. All certification and filing work is handled by ICAI-registered practising Chartered Accountants.