The UK Supreme Court delivered its judgment in the Prudential case yesterday, confirming by a majority of five to two that legal advice privilege (LAP) cannot be claimed to protect confidential communications between accountants and their clients for the purpose of requesting or providing legal advice, even in tax matters.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap