Advisers risk 'sleepwalking' into criminal prosecution

"We have worked extensively with businesses and professional representatives to support them to ensure they understand the new law and can implement the right systems to prevent the facilitation of evasion.

"We have seen many businesses react very positively to this and change their systems and behaviour. We have produced guidance and given businesses an easy way to self-report."

But the tax office added: "We also intend to criminally investigate where that is appropriate and to send a strong deterrent message to those who don’t take the new law seriously.

"The offence only applies where the evasion and the facilitation of it took place after September 2017 and investigations are likely to be complex.

"Progress in identifying and carrying out investigations is in line with our plans. There are further cases in our pipeline."