Richard Collier-Keywood UK Head of Tax at PricewaterhouseCoopers provides further thoughts on legal professional privilege as it applies to the new tax avoidance disclosure regime
Almost the first substantive issue that came up after the announcement of the Tax Avoidance Disclosure (TAD) regime in the March Budget was Legal Professional Privilege (LPP): would lawyers have to comply? In the first meeting on TAD in the wake of the Budget the issue was raised that privilege would mean lawyers were not able to comply and indeed that Bar Council rules meant that barristers could not comply. I've had my doubts about this (and I am a barrister!). Meanwhile the Inland Revenue's view has always been that privilege was simply not an issue: it was not asking for anything that was confidential such...
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Richard Collier-Keywood UK Head of Tax at PricewaterhouseCoopers provides further thoughts on legal professional privilege as it applies to the new tax avoidance disclosure regime
Almost the first substantive issue that came up after the announcement of the Tax Avoidance Disclosure (TAD) regime in the March Budget was Legal Professional Privilege (LPP): would lawyers have to comply? In the first meeting on TAD in the wake of the Budget the issue was raised that privilege would mean lawyers were not able to comply and indeed that Bar Council rules meant that barristers could not comply. I've had my doubts about this (and I am a barrister!). Meanwhile the Inland Revenue's view has always been that privilege was simply not an issue: it was not asking for anything that was confidential such...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
