Recent experience suggests that HMRC are increasingly challenging taxpayers’ claims to withhold privileged documents from disclosure during a tax enquiry or dispute. It is now more important than ever for taxpayers to consider the rules of privilege from the earliest stages of a transaction in order to avoid sensitive documents from being disclosed to HMRC. Questions continue to arise in particular over the status of documents created during internal fact-finding investigations, and care must be taken to mitigate against the risk of disclosure. Taxpayers should also be mindful not to indiscriminately forward or share email chains which contain legal advice.
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Recent experience suggests that HMRC are increasingly challenging taxpayers’ claims to withhold privileged documents from disclosure during a tax enquiry or dispute. It is now more important than ever for taxpayers to consider the rules of privilege from the earliest stages of a transaction in order to avoid sensitive documents from being disclosed to HMRC. Questions continue to arise in particular over the status of documents created during internal fact-finding investigations, and care must be taken to mitigate against the risk of disclosure. Taxpayers should also be mindful not to indiscriminately forward or share email chains which contain legal advice.
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:
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