CONFIDENTIALITY, PRIVILEGE AND THE TAX ADVISER CUSTOMS & EXCISE APPROACH Michael Conlon QC PUMP COURT TAX CHAMBERS.

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Presentation transcript:

CONFIDENTIALITY, PRIVILEGE AND THE TAX ADVISER CUSTOMS & EXCISE APPROACH Michael Conlon QC PUMP COURT TAX CHAMBERS

TOPICS COVERED 1.Introduction 2.Statutory powers 3.LPP and the C&E SP 4.Conclusions PUMP COURT TAX CHAMBERS

INTRODUCTION (1)Customs duties (2)Excise duties (3)VAT (4)IPT (5)Landfill tax (6)Climate change levy PUMP COURT TAX CHAMBERS

OVERVIEW (1) and (2):CEMA 1979 (3) Sch 11, VATA (4) Sch 7, FA 94 (5) Sch 5, FA 96 (6) Sch 6, FA 2000 also PACE 1984 PUMP COURT TAX CHAMBERS

SPECIFIC PROVISIONS VATA 1994, Sched 11 para 7 para 10 para 11 paras PUMP COURT TAX CHAMBERS

FURNISHING INFORMATION Every person concerned in Supply, acquisition, importation Reasonably require Specific PUMP COURT TAX CHAMBERS

PRODUCING DOCUMENTS As for information (and 3rd party) Documents (incl. P&L, balance sheet) Reasonably require Specific PUMP COURT TAX CHAMBERS

ENTRY AND SEARCH Inspection Search warrant Reasonable ground (fraud offence) Terms of warrant Seize/remove documents or things PUMP COURT TAX CHAMBERS

PRODUCTION ORDERS COPIES PUMP COURT TAX CHAMBERS

LEGAL PROFESSIONAL PRIVILEGE Nature of right Relationship with C&E powers Black sacks and Popely PUMP COURT TAX CHAMBERS

C&E STATEMENT Tax adviser Confidential tax advice Included? Mixed material “Legal” override? PUMP COURT TAX CHAMBERS

CONCLUSIONS Scope of the C&E SP Non-VAT cases Effect of Morgan Grenfell Limited shelf-life? Points to watch PUMP COURT TAX CHAMBERS

Confidentiality, Privilege and the Tax Adviser A Half-Day Seminar Wednesday 16 October 2002