Court of Appeal
Regina (Morgan Grenfell & Co Ltd) v Special Commissioner of Income Tax and another
[2001] EWCA Civ 329
2000 Oct 16, 17;
Nov 8
2001 Feb 12, 13;
March 2
Buxton LJ and Penry-Davey J Schiemann, Sedley LJJ and Blackburne J
PracticeDiscoveryPrivilegeProfessional privilegeTax inspector's investigationInspector seeking special commissioner's consent to give notice requiring taxpayer to disclose documents attracting legal professional privilegeCommissioner refusing inter partes and giving consentWhether statutory disclosure regime excluding legal professional privilegeWhether inspector entitled to give notice in respect of privileged documentsWhether taxpayer entitled to oral hearing before commissioner Taxes Management Act 1970 (c 9), s. 20(1)(7) (as substituted by Finance Act 1976 (c 40), s. 57(1), Sch. 6) [1] Human Rights Act 1998 (c 42), Sch. 1, Pt I, art 8 [2]

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