The High Court decided in Reid that a solicitor's advice to his clients was not privileged as it related to the establishment of a tax avoidance scheme where there was a prima facie case that the solicitor knew the scheme did not work, even if his clients did not. This suggests that the High Court has extended the law on third party iniquity beyond that already recognised, which will impact other mass-marketed tax avoidance schemes. It is the first tax case involving the iniquity principle, as well as forming a beachhead in HMRC's use of their criminal powers.