A fresh clampdown on tax evasion by HMRC, which may include larger fines, has been met with criticism by tax consultancy boutique Milestone.
Earlier this week HMRC announced tough new guidelines that included fines and criminal charges for those who do not come forward and pay outstanding tax from offshore investments and accounts.
Described as 'game-changing' by financial secretary to the Treasury Jane Ellison, it has instead been called 'dangerous' by Milestone partner Tom Wesel.
'HMRC already has a very severe penalty regime for offshore evasion, which is further strengthened in the current Finance Bill. The new proposals look like overkill,' said Wesel.
'There is no requirement for fault or any intent to evade tax. So entirely innocent errors would be caught.
'If tax authorities cross the line from taxation by consent to bullying tactics, they risk losing the trust and cooperation that is essential for collecting tax.'
In particular, Wesel is concerned that those with offshore accounts will automatically assumed to be evading tax.
He added: 'Perhaps HMRC regard those with assets offshore as fair game. But this is a dangerous game for the state to play.
'Once HMRC lose the trust and consent of taxpayers, they end up like Mediterranean tax authorities, where despite extreme penalties cheating on tax is regarded as a national sport or civic duty.'