LEGAL-PRIVILEGE

Parallel HMRC and civil proceedings are best handled not as two separate problems to be dealt with in sequence, but as a single, interconnected strategic challenge, write James Le Gallais and Anastasia Nourescu (Stewarts).

Jason Collins

Lauren Redhead

Legal advice privilege (LAP) remains a vital right for taxpayers, but its boundaries are far from settled. Jason Collins and Lauren Redhead (DLA Piper) examine LAP in a tax context, including the recent decision in Aabar v Glencore which extends privilege to intra-client group communications.

SDLT appeal against closure notice:A Sajedi and others v HMRC [2026] UKUT 101 (TCC) (24 September 2025) concerned an arrangement which was designed to obtain the relief from higher rates of SDLT available where a person replaces his or her main...

Oliver Marre

Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.

Matthew Greene

Ian Hyde

Ian Hyde and Matthew Greene (Osborne Clarke) explain the basics of legal professional privilege and consider related practical issues in a tax context.

Dominic Stuttaford

Tax structuring advice received and implemented, even where there is a perceived risk of challenge, will not benefit from litigation privilege, writes Dominic Stuttaford (Norton Rose Fulbright).

Kate Ison

Kate Ison (Bryan Cave Leighton Paisner) reviews the department’s strategy.

Richard Jeens

Charles Osborne

Richard Jeens and Charles Osborne (Slaughter and May) explain the practical points to consider both when drafting the tax indemnity and in the management of any subsequent claims.

Jason Collins

Stuart Walsh

Jason Collins and Stuart Walsh (Pinsent Masons) review a recent tribunal case which highlights the practical difficulties of asserting legal privilege where the taxpayer has to explain their motivations behind a transaction.