Thanks for your replies, IMO the HMRC policy on whether you get the FREA very much depends on which regional office does your tax and the persons understanding of your job and the different jobs within commercial aviation.
At the moment the Gloucester and North Wilts office are currently taking the line that I'm not a commercial pilot as the FREA applies, although I hold a JAR commercial license and I fly helicopters for a living.
They laughingly wrote to me saying that the FREA was designed to compensate for the extra costs that commercial airline pilots incur because of having to eat whilst at the controls of their aircraft, leading to extra cleaning cost!
Needless to say I gave them numerous examples where the FREA wasn't solely introduced to compensate for extra cleaning costs.
I think I'll have a battle on my hands with my HMRC office and getting the FREA granted to me.
BALPA are helping me with this so hopefully I'll see how much clout they can have.
I guess that playing field isn't that flat after all