An application by HMRC for information notices relating to UK properties where a third-party notice was addressed to a firm of solicitors was not defeated by legal professional privilege, and the application was granted.â¯
On 22 November 2022, HM Revenue and Customs (HMRC) applied to the First-tier Tribunal (FTT) for a third-party information notice to be issued (under FA 2008, Sch 36, para 2) to the third party, a firm of solicitors in Northern Ireland. The third-party notice sought information on two properties where the firm acted for the taxpayer on their purchase (although HMRC withdrew one property from the application when it was established that the solicitors had not acted for the taxpayer) and a third property where the firm acted on the disposal.
The third party contended (among other things) that all the information and documents requested by HMRC in respect of the two remaining properties were protected by legal
