Summary: Hodge wants to make it a criminal offence to sell or promote illegal tax avoidance schemes in the first place. So if HMRC challenge a scheme and it's found illegal, the lawyers/accountants who developed it can be criminally prosecuted as well as those who used it.
Got to say I agree with this http://www.thetimes.co.uk/tto/news/politics/article4285739.e... (paywall).
Summary: Hodge wants to make it a criminal offence to sell or promote illegal tax avoidance schemes in the first place. So if HMRC challenge a scheme and it's found illegal, the lawyers/accountants who developed it can be criminally prosecuted as well as those who used it.