Unsuspecting advisers face £3k HMRC penalty

Speaking last year, Damian Bloom, a partner at law firm Berwin Leighton Paisner, said the vast majority of clients who receive the notices would be compliant.

"There is a risk of compliant clients wondering what the notice is about."

He told FTAdviser the new legislation follows on from the Liechtenstein Disclosure Facility which ran from 2009 to 2015 and offered opportunities for errant tax payers to come forward to HM Revenue & Customs.

In August 2015, tax experts Baker Tilly warned anyone with undisclosed overseas income, gains or assets would be wise to make use of the Liechtenstein Disclosure Facility while it lasts.

At that time, Andrew Hubbard, a partner at the firm, warned advisers that everything he has heard has led him to conclude that life for tax evaders will only get tougher following the phasing out of the facility.

A total of £1.5bn was taken under the Liechtenstein Disclosure Facility.