Information requests and protections for those receiving them are in the limelight this month. The latest High Court ruling on privilege follows the restrictive view of what constitutes a client for legal advice privilege and adopts a narrow reading of dominant purpose for litigation privilege. The CJEU holds that the courts of one member state may review the legality of requests for tax information sent by another member state to verify whether the information sought is manifestly devoid of any foreseeable relevance to the investigation concerned. As if taxpayers are not already feeling under pressure, the Upper Tribunal in the Henderson case takes a hard line on purposive construction.
