The Supreme Court has reserved judgement in R (on application of Prudential PLC) v Special Commissioner of Income Tax.
This is an interesting case which MAY extend Legal Professional Privilege (LPP) to accountants advising on tax issues. We say MAY, because the current approach to LPP has been to restrict and undermine it. The lower courts have historically been of the view that any extension of LPP is a matter for statute and not the courts.
LPP currently concerns communication, advice and/or opinions between a lawyer and his/her client when litigation is either pending or contemplated.
