Patrick Cannon considers whether new regulations which provide a procedure for dealing with disputes between the taxpayer and HMRC over legal privilege are what they seem
HMRC has long been suspicious of legal professional privilege ('LPP') and appears to regard it as an unfair obstacle to HMRC's natural bureaucratic desire to know everything relevant about those citizens it decides to investigate. Accountants and other non-lawyer tax advisers are jealous of LPP because they don't have it and regard LPP as giving lawyer tax advisers an unfair competitive advantage. To make matters worse LPP is rarely covered in any detail on law degree courses nor on solicitors' or barristers' professional courses so many English lawyers have only a limited understanding of LPP. This situation can be contrasted with other common-law jurisdictions — such as...
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Patrick Cannon considers whether new regulations which provide a procedure for dealing with disputes between the taxpayer and HMRC over legal privilege are what they seem
HMRC has long been suspicious of legal professional privilege ('LPP') and appears to regard it as an unfair obstacle to HMRC's natural bureaucratic desire to know everything relevant about those citizens it decides to investigate. Accountants and other non-lawyer tax advisers are jealous of LPP because they don't have it and regard LPP as giving lawyer tax advisers an unfair competitive advantage. To make matters worse LPP is rarely covered in any detail on law degree courses nor on solicitors' or barristers' professional courses so many English lawyers have only a limited understanding of LPP. This situation can be contrasted with other common-law jurisdictions — such as...
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If you do not subscribe but are a registered user, please enter your details in the following boxes: