DAC Beachcroft v HMRC

Cathya Djanogly

In DAC Beachcroft v HMRC [2018] UKFTT 502 (6 September 2018) the FTT found that legal advice privilege (LAP) applied to conveyancing documents which were the subject of a third-party notice (FA 2008 Sch 36 para 2).

DAC a law firm applied for a declaration that conveyancing files (created by its predecessor firm) were privileged. The relevant three properties had been purchased in the names of three separate offshore companies but HMRC was aware (as a result of a report made to it under the Liechtenstein Disclosure Facility) of the involvement of a fourth offshore company in at least two of the purchases. HMRC therefore sought to establish whether that fourth company was centrally managed and controlled in the UK.

HMRC had written to DAC informing it that it was intending to issue a third-party information notice. The FTT had duly approved the notice but...

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