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Privilege and the Disclosure Regime

Sarah Falk Tax Partner and Sean Jeffrey Dispute Resolution Senior Associate Freshfields Bruckhaus Deringer set out the current thinking of the 'magic circle' law firms on LPP and the disclosure regime
In their article in The Tax Journal 25 October 2004 Issue 762 Hartley Foster and Aileen Barry of DLA discussed the direct tax disclosure regime under the Finance Act 2004 (the Act) and related regulations (the Disclosure Regime). A further article by Richard Collier-Keywood on 1 November 2004 Issue 763 raised specific issues in relation to legal professional privilege (LPP).
Under s 314 of the Act no disclosure need be made that would breach the rules of LPP. Section 314(1) provides: 'Nothing in this Part requires any...
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