Alan Bowen, legal advisor to the Association of Atol Companies, said: “Bed banks told HMRC [in the Medhotels case] they weren’t liable to pay VAT because they were acting as agents. But with the failure of Lowcost, no hotel has taken responsibility.

“They’ve ignored the suggestion that people had appointed Lowcost as their agent. The tax man will be after every bed bank because they’ve now got real proof that these hotels will wash their hands of a company [if that company fails].”

Consultant Andy Cooper of Owens Cooper Consulting agreed that HMRC may use this as an opportunity to return its focus back onto the travel industry.

“They definitely might do that,” he said, but added: “Lowcost may not have been acting as an agent but that’s not proof that everyone else isn’t.

“The documentation between the hotel and travel company is the proof – that will be the document that makes it clear if they’ve been acting as an agent or not.

“With Medhotels they were able to demonstrate that they were acting as an agent. It could be that the hotels have chosen to ignore [Lowcost] and customers could challenge that.”

Steve Endacott, founder of On Holiday Group, who blamed HMRC for the failure of his company in March 2014, said: “In my view, it’s all about the contractual behaviour. If you look at the legal contract, the commercial terms will state whether the money needs to be held in trust, and that’s between the two parties [the hotel and agent] and nothing to do with HMRC.”

Meanwhile, it has since emerged that Lowcosttravelgroup, founded by Paul Evans in 2004, was in the process of trying to recoup money back from HMRC, thought to be just under £1.3 million, at the time of its collapse.

The bed bank business was moved to Switzerland in 2009.