10 out of 12 documents requested by HMRC in an information notice issued to the applicant were subject to legal professional privilege.
On 21 November 2019, HM Revenue and Customs (HMRC) issued the applicant with an information notice (under FA 2008, Sch 36, para 1) requiring disclosure of certain documents in order that HMRC could check the applicant’s tax position for the tax year 2002/03.
The applicant’s representative appealed against the notice and notified HMRC
