That first list essentially provided support for those accountants who have already chosen NOT to advice on such schemes. Below I have listed five more facts which should also be borne in mind by those accountants who are nonetheless tempted to look further into the subject:
- Encouraging a client to undertake a structured tax avoidance scheme is much like encouraging them to make a specific investment;
- It takes a fair amount of time to get to grips with all of the relevant details of a structured tax avoidance scheme;
- HMRC may announce a change in the law at any moment - leading to rushed (and perhaps botched) attempts to revise the scheme by the promoters;
- Having committed all that time to learning about the scheme there may be a temptation to persuade someone to 'invest' even if they might not otherwise choose to do so;
- If, some years later, the scheme is ultimately held not to work the client may sue the accountant for failing to adequately highlight the risks.