In a major break with settled practice, Stephen Oliver QC, Inland Revenue Special Commissioner has ruled that UK companies' dealings with their legal advisers (traditionally protected against disclosure) can be accessed by the Inland Revenue if they concern a tax liability. Although the ruling will be appealed, it may turn out to be the thin end of the wedge. Companies can perhaps protect themselves, however, by taking their tax advice offshore, where the Inland Revenue is much less likely to be able to get at it. This certainly can't harm the business prospects of offshore tax advisers!
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