Combining the Inland Revenue and Customs and Excise into what is now HMRC and providing the department with greater powers aligned across all taxes has provided an opportunity for greater and more effective compliance activity.

Arguably, the UK budget deficit is just the kick in the pants HMRC needed to pursue the opportunity vigorously.

Fee protection insurers – who pay for the professional costs of defending taxpayers in HMRC investigations – have seen plenty of evidence of this in the last few years.