HMRC has issued guidance setting out how legal professional privilege operates when the tax authority investigates and pursues tax avoidance cases. The guidance covers the application of privilege across disputes, information disclosure obligations, enabler penalties, scheme declarations and HMRC’s powers to publish details about avoidance arrangements. This clarification helps advisers and taxpayers understand which communications with legal representatives remain protected during avoidance-related inquiries and enforcement actions.
Source: HMRC (GOV.UK) – Read the original