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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Conditions and safeguards: Restrictions: Relevant communications

Relevant communications are communications

  • between a tax adviser (including a voluntary sector adviser) and

    • the person in respect of whose tax affairs the adviser has been appointed to act, or
    • any other tax adviser of that person, and
  • whose purpose is to give or obtain advice about any of that person’s tax affairs.

A document containing relevant communications must be the tax adviser’s property, that is, it must belong to the adviser. If it belongs to the client it will not be protected by the restriction.

Relevant communications may be in the form of

  • letters
  • emails
  • faxes
  • notes of telephone conversations, or
  • notes of meeting.

FA08/SCH36/PARA25 (3)

CEMA79/S118BA