The topical guidance is intended to be read alongside the main PCRT guidance when considering the ethical use of AI for tax work. It: 

• explains what is meant by AI;
• gives examples of how AI tools could be used in tax; and
• considers the use of AI tools in the context of the PCRT fundamental principles, including identifying possible ethical risks and safeguards to implement. 

Key messages 

The topical guidance reminds members that they are ultimately responsible for any work they produce, and for regulated firms, any work which the firm prepares, irrespective of the use of AI tools in its creation. Therefore, it is essential that members oversee any work facilitated by AI tools appropriately and diligently. Attention is drawn to PCRT paragraph 3.2 which outlines the standards for tax planning, including the requirement for members to apply professional judgement.  

Where a member is not familiar with the use of AI, but is seeking to use AI tools as part of the services provided to a client, the topical guidance suggests that they may need to consider consulting an appropriate AI specialist in order to undertake the work. 

Fundamental principles 

• Integrity. Members should be straightforward and honest in their professional and business relationships by:
  • considering the level of transparency provided to clients in relation to the use of AI tools;
  • ensuring they can explain how a conclusion was arrived at; and
  • giving careful consideration to the level of reliance placed on any AI-generated data.

• Objectivity. Members should manage the risk of bias by having an awareness of the data sources used (where possible) and how their own unconscious bias may impact their interpretation of data sources and the generated results. 

• Professional competence and due care. Members should carry out their work with proper regard for the technical and professional standards expected of them by:
  • ensuring they are sufficiently competent in the use and implementation of AI tools and that staff receive appropriate training for any AI tool used;
  • performing due diligence on the output from the AI tool using a risk-based approach; and
  • exercising due care and professional scepticism in determining if the data output accurately represents the client's specific circumstances and aligns with current legislation, etc. 

• Confidentiality. Inputting a client’s data into a publicly available AI model without their consent is likely to constitute a breach of client confidentiality. Steps should be taken to ensure that the data is anonymised and generic so that the client cannot be identified. Any data handling requirements should also be considered, and specialist legal advice may be required depending on the circumstances.  

• Professional behaviour. Members should ensure that any AI generated data used as part of the work complies with their legal and regulatory obligations by:
  • understanding the limitations of the AI tool;
  • exercising additional caution when using an AI tool that generates tax planning advice; and
  • reviewing correspondence prepared by an AI tool to ensure that the tone and content is appropriate. 

What is PCRT? 

PCRT consists of the fundamental principles and the standards for tax planning. ICAEW members working in tax must be familiar with and comply with PCRT; failure to do so may result in disciplinary action.  

Further help and support 

ICAEW members can seek further guidance on the ethical considerations of using AI in tax: 

• at icaew.com/regulation;
• via ICAEW Ethics Enquiry Line on 01908 248250 and ethics@icaew.com; and 
• from the Support Members Scheme 0800 917 3526 and support.members@icaew.com.  

Where appropriate, guidance may be required from specialist or legal advisers.