HMRC made it clear that this is not "avoidance" it is "evasion". HMRC have ran a number of disclosure opportunities and I would imagine that once the first agency returns go in (planned November 2014) and they cross check to their SA and other secret databases, that letters will start to drop through those concerned letter boxes asking them to advise why there is a gap in their tax records and do they want to make a voluntary declaration.
HMRC also confirmed that they intend to use their powers fully to prevent non-compliant providers, who basically have ran their companies with a view to fail, re-opening.
HMRC also agreed that they need to tidy up their descriptions as the definitions had started to cause confusion in the market place.
Watch this space...