Certain documents requested by HMRC in an information notice were subject to legal advice privilege, and the applicants were not obliged to disclose any part of them.  

HM Revenue and Customs (HMRC) issued information notices (under FA 2008, Sch 36)  

during its enquiries into the applicability of diverted profits tax (DPT) to arrangements between certain subsidiaries of the first applicant and a number of subsidiaries of the second applicant (‘TRUK entities’) for the accounting periods ending 31 December 2016, 2017, and 2018, during which time the first applicant was part of the second applicant. The arrangements included the transfer of trademarks and other intellectual property from TRUK entities to the Swiss principal entity (‘TRGR’) from 2008 onwards. 

The appellants asserted legal privilege in respect of certain documents requested by HMRC. Pursuant to the Information Notice: Resolution