Heather Gething and Andrew Cooke review the Supreme Court judgment in Prudential. Ian Young provides a view from the ICAEW.
Disclosure of documents in any dispute enables a proper investigation of the parties' rights and liabilities by placing before the court all of the documents that are relevant to assessing those liabilities. The requirement for a taxpayer to disclose relevant documents to HMRC in the context of a tax dispute is the same as applies in a commercial dispute but is limited where those documents are covered by LAP a fundamental human right which permits a taxpayer to obtain advice from a qualified lawyer without fear that the communications in which that advice is sought or provided will be disclosable.
Where LAP applies a taxpayer can withhold a document from disclosure to HMRC. The effect of LAP is therefore...
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Heather Gething and Andrew Cooke review the Supreme Court judgment in Prudential. Ian Young provides a view from the ICAEW.
Disclosure of documents in any dispute enables a proper investigation of the parties' rights and liabilities by placing before the court all of the documents that are relevant to assessing those liabilities. The requirement for a taxpayer to disclose relevant documents to HMRC in the context of a tax dispute is the same as applies in a commercial dispute but is limited where those documents are covered by LAP a fundamental human right which permits a taxpayer to obtain advice from a qualified lawyer without fear that the communications in which that advice is sought or provided will be disclosable.
Where LAP applies a taxpayer can withhold a document from disclosure to HMRC. The effect of LAP is therefore...
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:
