The new regime follows a consultation undertaken in August 2016, which proposed to introduce fines for accountants and other tax specialists for ‘enabling’ tax avoidance.

In the consultation, which finished on 12 October 2016, it was suggested that fines could be imposed on accountants who promote the schemes at up to 100% of the value of the unpaid tax.

Critics of the plans have warned they could result in them being punished simply for giving their opinion on the legality of tax arrangements.

While details will be published in draft legislation ‘shortly’, the move will be included in the Finance Bill 2017.

The government will also remove the defence of having relied on non-independent advice as taking ‘reasonable care’ when considering penalties for any person or business that uses such arrangements.

ACCA head of tax Chas Roy-Chowdhury said: ‘Under the proposed changes, an individual or business who has undertaken tax avoidance and are proved to be incorrect in a court of law will incur a penalty.

‘However, under the advance payments regime, the tax would have been paid up front already, which makes an additional penalty unwarranted, and somewhat draconian.’