Yup I get that because if you are any good you work on the other side. That's why I made my suggestion accountants will always push the envelope but if they are required to get approval both they and their clients will know what they are getting into and HMRC has to decide if it wants to fight a scheme or not.

The other thing to do is to simplify the tax system the more complicated it is the more it favours the tax dodgers. Dumb it down so you don't need rocket scientists at HMRC just good people.