Your World of Legal Intelligence
 United Kingdom | +44 (0) 20 7284 8080

Chapter CH22266

Document Cited in Related
Vincent
Published date11 March 2016
Record NumberCH22266
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

You must consider who gave the advice to the person whose tax position you are reviewing as this affects what you can require.

Advice from a legal professional

If the advice was given by a legal professional such as a solicitor, lawyer or legal counsel you cannot require a person to provide items that are legally privileged. For the advice to be legally privileged it must fall within one of the two types of privilege, Legal Litigation Privilege (LLP) or Legal Advice Privilege (LAP). See CH22240 for further guidance on legal professional privilege. Tax advice provided by such a legal professional is likely to fall within LAP and therefore you will not be able to require it in an information notice, see CH22242-54.

Advice from...

To continue reading

Request your trial

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT