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Disclosing Privilege

Richard Collier-Keywood, UK Head of Tax at PricewaterhouseCoopers, provides further thoughts on legal professional privilege as it applies to the new tax avoidance disclosure regime

 
Richard Collier-Keywood UK Head of Tax at PricewaterhouseCoopers provides further thoughts on legal professional privilege as it applies to the new tax avoidance disclosure regime
 
Almost the first substantive issue that came up after the announcement of the Tax Avoidance Disclosure (TAD) regime in the March Budget was Legal Professional Privilege (LPP): would lawyers have to comply? In the first meeting on TAD in the wake of the Budget the issue was raised that privilege would mean lawyers were not able to comply and indeed that Bar Council rules meant that barristers could not comply. I've had my doubts about this (and I am a barrister!). Meanwhile ...

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