HM Revenue & Customs has indicated that a second ‘amnesty’ is on the cards, but suggested the opportunity would only be for account holders at the banks targeted by the taxman’s second wave of disclosure orders.

Baker Tilly head of tax George Bull told Accountancy Age that the taxman would find it ‘impossible’ to start another facility. ‘They are opening themselves up to major challenges if the second facility is restricted to the second set of banks. You’d have a situation where the penalties you face [as a tax evader] depend on where you bank. There’s no certainty, or fairness,’ said Bull.

Dave Hartnett, now acting chairman at HMRC, said a fortnight ago: ‘We want to offer something similar to those who haven’t received letters from their banks. We haven’t quite worked out how to do it yet.’

Plans for a second offshore facility are on hold, advisers suggested, while the taxman works on the fiasco over the lost child benefit data. HMRC is understood to be pressing ahead with the moves, however.