So the big clampdown on accountants and advisers, not to mention any bank, lawyer or independent financial adviser involved in a dubious tax avoidance scheme, has started. In the latest act, the government has set out plans for punitive sanctions for tax advice which falls foul of current law.

The aim no doubt to frighten off any accountants considering a creative scheme with the threat of a fine which could be up to 100% of tax avoided; but this is the crux of the problem. The authorities persist in describing the activity as avoidance, in the next breath claiming that it is not illegal, only aggressive, and hence abusive. Perhaps extreme avoidance is a better definition.