HMRC has declared that ‘if you are hiding undeclared income offshore, (we are) closing in on you. So come forward now before (we) come to you’. This tough talk in HMRC’s recent consultation paper Tackling offshore tax evasion: A new criminal offence, sounds reminiscent of Christian Bale playing Batman or a line from one of the characters in the soon to be screened Sin City 2.

While one might imagine the threatening power of HMRC from its language, with its workers watching out for those who are evading tax in black suits ready to pounce, the reality is that the effectiveness of these new powers in the battle against tax evasion is far from certain.