In a speech to the institute?s Nottingham conference, Keith Daniels warned the profession it was now in a new, aggressive era and was entering the early stages of a potential conflict which could damage future relationships.
Daniels? criticisms centred on what he termed an ?inherently unfair? criminal prosecution policy by the Revenue. He also predicted that there was every possibility of a rapid increase in the number of criminal prosecutions for clients.
A Revenue spokeswoman dismissed the claims, and said that its stance on prosecuting tax fraud had not changed.
?We will prosecute anybody who does commit fraud, especially in cases of falsification of documents, lying during an investigation, conspiracy if we discover false documents during an early investigation, or dishonesty on the part of a professional tax adviser.
?But there are other areas we will prosecute as much as we can in order to deter tax fraud,? the spokeswoman said.
Daniels also told the conference that, although a great deal of consultation had taken place between the institute and the Revenue in the past, ?there does not appear to be the same open-minded approach that we saw with the original development of the personal tax-assessment system?.
The CIoT will shortly revise its Professional Rules and Practice Guidelines. Daniels said: ?There is an urgency to give such guidance to members so that they can respond to this new, aggressive era.?