And some their solvency.

Robert Huitson used a scheme on the Isle of Man, set up up by Montpelier Tax Consultants, which paid an annual fee for being the owner of a life interest in an offshore trust. When he received a request for £100,000 of backdated tax from HMRC he challenged it using human rights legislation in what became a test case.

Justice Parker, hearing the case, said that the scheme ‘would appear to realise every taxpayer’s dream of lawfully avoiding, or at least greatly reducing, income tax in any jurisdiction’.

The case failed and now Huitson and other participants in scheme face retrospective claims from HMRC.

Justice Parker added: ‘I note that according to the evidence in this claim, HMRC intends to take into account financial hardship to taxpayers before seeking to enforce demands for tax and interest in respect of past periods’.

Right now that’s probably a fair bit. Horrible timing.