R (PRUDENTIAL PLC AND ANOTHER) v SPECIAL COMMISSIONER OF INCOME TAX AND ANOTHER (INSTITUTE OF CHARTERED ACCOUNTANTS IN ENGLAND AND WALES AND OTHERS, INTERVENING)

[2011] Lloyd's Rep FC Plus 1

COURT OF APPEAL (CIVIL DIVISION)

Before Lord Justice Mummery, Lord Justice Lloyd, and Lord Justice Stanley Burnton

HMRC investigation - Production of documents - Tax advice from accountant - Whether legal professional privilege applied - Taxes Management Act 1970, section 20 - European Convention of Human Rights, article 8