Prudential plc & Anor, R (on the application of) v Special Commissioner of Income Tax & Anor

The appellant companies (P) appealed against a decision that legal advice given by accountants in respect of tax matters was not covered by legal advice privilege. The Revenue had issued a notice requiring disclosure of documents relating to a tax avoidance scheme. P refused to disclose documents containing legal advice from their accountants on the basis of legal advice privilege. The appeal was dismissed.

It was held the appeal would stretch the limits of legal advice privilege too greatly. Legal advice privilege would not be extended to communications in connection with advice given by professional people other than lawyers, even where that advice was legal advice which that person was