Behague v HMRC [2013] UKFTT 596 (TC)

Wills & Trusts Law Reports | March 2014 #137

HMRC opened an enquiry into Mr Behague’s (the appellant) self-assessment return and issued a notice to the appellant under para 1 of sch 36 of the Finance Act 2008. This notice requested the provision, to HMRC, of a client engagement letter and a report issued to the appellant by his solicitors. The appellant appealed this notice and claimed legal professional privilege (LLP) applied to the documents.

HMRC accepted that communications between a solicitor and his client were privileged to the extent they related to the giving or obtaining of legal advice, however HM...