[2018] EWHC 626 (Admin)

High Court (Queenʼs Bench Division)

The Honourable Mrs Justice Whipple

Judgment delivered 23 March 2018

Judicial review – Whether HMRC acted unlawfully by inducing a breach of confidence – Had there been inducement – No – Did FA 2004, s. 316B apply to permit HMRC to receive the disclosures anyway – Yes – Whether tax advice letters were subject to legal professional privilege (LPP) – No – Judicial review dismissed.

  The High Court dismissed the claimantsʼ judicial review claim that HMRC had acted unlawfully when they received information about 2 tax schemes.


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