The Weekly Law Reports
[2013] 2 WLR 325
Supreme Court
Regina (Prudential plc and another) v Special Commissioner of Income Tax and another (Institute of Chartered Accountants of England and Wales and others intervening)
[2013] UKSC 1
2012 Nov 5,
6,
7;
2013 Jan 23
Lord Neuberger of Abbotsbury PSC, Lord Hope of Craighead DPSC, Lord Walker of Gestingthorpe, Lord Mance, Lord Clarke of Stone-cum-Ebony, Lord Sumption, Lord Reed JJSC
Practice— Discovery— Legal professional privilege— Accountants advising taxpayer company on tax law— Inspector of taxes serving notices requiring disclosure of communications passing between taxpayer and accountants— Whether advice given by accountants on tax law protected by legal advice privilege— Whether material sought privileged—
Taxes Management Act 1970 (c 9), s 20(1)(3) (as substituted by Finance Act 1976 (c 40), s 57(1), Sch 6 and amended by Finance Act 1989 (c 26), s 142)