Airline Placement and disclosure

What do you say when your client wants absolute assurance that HMRC will agree with your proposed tax treatment of a particular transaction? Your client of course trusts your advice particularly as you explain to them that you are a fully qualified tax professional with years of experience an unblemished professional indemnity insurance (PII) record and undertake comprehensive continuing professional development including reading Taxation magazine every week from cover to cover. But when your client says: ‘I get all of that Andrew but I’d still like to get HMRC’s agreement before I proceed’ – what do you do?

I’m sure that we have all been faced with this issue at some point in our careers. Sometimes the context will be a significant one-off deal where the amount of tax at stake is material. At other times the client might be putting together a commercial proposition...