But Ronnie Ludwig, at accountants Saffery Champness, said HMRC was firing a broadside at all such schemes.

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Pete Hackleton, a partner in the London office of accounting firm Saffery Champness who specialises in the sport and entertainment businesses, agrees.

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Ronnie Ludwig, of accountants Saffery Champness, said the High Court ruling meant that users of other "off the shelf" tax avoidance schemes could no longer sleep easily.

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"If you look at these websites it is obvious that people have got a stock of goods they are selling, and hiding the proceeds in undeclared offshore bank accounts, " said Ronnie Ludwig of accountants Saffery Champness.

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Ronnie Ludwig, a partner in the accountancy firm Saffery Champness in Edinburgh and a former tax inspector with expertise in tax havens, says he could argue with the numbers in the report, but not with the sentiments it expresses.

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