Market leading insight for tax experts
View online issue

Litigation privilege and structuring advice

Speed read
In Financial Reporting Council Ltd v Frasers Group plc, the High Court held that the commission of VAT structuring reports in response to an anticipated challenge did not satisfy the ‘sole or dominant purpose’ test for conducting litigation. The court further noted that tax structuring reports are created for the purpose of achieving a particular tax result and not for the purpose of conducting litigation. The case illustrates the limited scope of litigation privilege; this is clearly important when legal advice privilege is not available.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.