I am sure there exist unbelievable creative advisers, which have the best ever ideas on tax planning, despite of BEPS and all current measures to reduce international abuses, and which have themselves never prepared (or reviewed) the tax return of the first year in which their client acted as advised.
Can you (as a professional or a client) imagine such a situation? I can.
Now there are clients which will sue the adviser for wrong advice. The bigger the advisory firm, the longer the so-called disclaimer, resulting in a comfortable situation for the adviser and a loss of the claim for the client. Other clients hesitate to sue their adviser, as a legal proceeding may attract the press to reveal names. Especially private clients (so-called “High Net Wealth Individuals”), will most probably prefer the loss of money, compared to the reputational risk in the event the transaction or its outcome will become known to the public.
A client asking his tax accountant to provide for successful tax planning ideas, may not receive any input. Again, the client will not be happy (at least there is no reputational risk).
The ideal adviser needs to have the knowledge of the clients’ accountant as to his situation and he oversees the feasibility of a transaction, while at the same time, he has the ideas of the brilliant guy. Or, the other way round, the brilliant top adviser needs to know how the basic homework is done, before he offers magnificent solutions.