REID v COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS AND OTHERS

[2025] Lloyd's Rep. FC Plus 24

CROWN COURT AT SOUTHWARK

Before Mr Justice Foxton

Legal professional privilege – Crime-fraud exception – Iniquity exception – Whether exception applied to seized material – Conspiracy to cheat public revenue – Criminal Justice and Police Act 2001, section 59(2) – Whether tax due on Disguised Remuneration Loans under Finance (No 2) Act 2017, schedule 11 and Income Tax (Earnings and Pensions) Act 2003, Part 7A.