Regina v A Special Commissioner ex parte Morgan Grenfell and Co Ltd; Regina v Martyn Rounding (HM Inspector of Taxes) ex parte Morgan Grenfell and Co Ltd: CA 2 Mar 2001

The inspector of taxes had power to issue a notice requiring access to legally privileged material. The power given by the section included certain exceptions, and those were not to be extended. The special or general commissioners had no power to hear from a taxpayer oral representations as to the issue of such a notice. The statutory procedure requiring the inspector to place all matters before the commissioner when applying for the commissioner’s consent to the notice was a substitute for any inter partes procedure, and displaced any such entirely.


Gazette 03-May-2001, Times 17-Apr-2001, [2001] EWCA Civ 329




Taxes Management Act 1970 20(1)


England and Wales


Appeal fromRegina v A Special Commissioner, ex parte Morgan Grenfell and Co Ltd Admn 8-Nov-2000
The rights of the inspectors to demand papers under the Act could override the protection of legal privilege which might otherwise be given to them. Construing the Act as a whole it was clear that legal professional privilege was not respected save . .

Cited by:

CitedThree Rivers District Council and others v Governor and Company of the Bank of England (No 6) HL 11-Nov-2004
The Bank anticipated criticism in an ad hoc enquiry which was called to investigate its handling of a matter involving the claimant. The claimant sought disclosure of the documents created when the solicitors advised employees of the Bank in . .
Appeal fromRegina v Special Commissioner And Another, ex parte Morgan Grenfell and Co Ltd HL 16-May-2002
The inspector issued a notice requiring production of certain documents. The respondents refused to produce them, saying that they were protected by legal professional privilege.
Held: Legal professional privilege is a fundamental part of . .
Lists of cited by and citing cases may be incomplete.

Taxes Management, Legal Professions, Income Tax

Updated: 31 May 2022; Ref: scu.147457