A Member in Public Practice providing tax planning services recommends a tax treatment only where it has a credible basis in applicable laws and regulations, reached through a reasoned analysis of the facts, and does not advise on arrangements whose purpose is to exploit a technical reading the authorities are unlikely to accept. The Member considers the reputational and public interest consequences of the arrangement, discloses uncertainties and alternative positions to the client, considers whether to decline or withdraw where the client insists on an arrangement without a credible basis, and documents the basis for the advice. The Australian paragraph AUST R380.26 adds a requirement to satisfy oneself that the recommended treatment is likely to prevail if challenged.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.