R (on the application of Emblin & Ors) v R & C Commrs  BTC 15
 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.