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).
In the evolving landscape of increased scrutiny and regulation of the audit profession audit clients are being increasingly drawn into the crossfire between regulator and auditor. Financial Reporting Council Ltd v Frasers Group plc (formerly Sports Direct International plc) [2020] EWHC 2607 (CH) is the first of what will likely be many cases involving the disclosure of privileged documentation for an investigation by the Financial Reporting Council (FRC) into auditor conduct. As a result of the dispute the taxpayer was forced to disclose certain tax planning advice the nature of which but for the dispute may not have become known publicly.
This case concerned the disclosure of three reports commissioned by Deloitte in respect of Sports...
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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).
In the evolving landscape of increased scrutiny and regulation of the audit profession audit clients are being increasingly drawn into the crossfire between regulator and auditor. Financial Reporting Council Ltd v Frasers Group plc (formerly Sports Direct International plc) [2020] EWHC 2607 (CH) is the first of what will likely be many cases involving the disclosure of privileged documentation for an investigation by the Financial Reporting Council (FRC) into auditor conduct. As a result of the dispute the taxpayer was forced to disclose certain tax planning advice the nature of which but for the dispute may not have become known publicly.
This case concerned the disclosure of three reports commissioned by Deloitte in respect of Sports...
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:
