Taxpayers who fail to declare assets held overseas face tough new sanctions that include a strict liability criminal offence, under HMRC proposals that have been strongly criticised by tax professionals as “draconian”.

Two consultation documents lay out plans to strengthen civil deterrents against evasion by broadening and modernising the scope of the offshore penalties regime and introducing measures aimed at preventing evaders moving their offshore assets from one jurisdiction to another – which could see the suspension of the 20-year investigation limit on tax affairs.

The Revenue also intends to introduce the crime of failing to declare taxable offshore income, which, like many other tax offences, would not require demonstration of …