Resolution of disputes as to legal privilegeU.K.
36(1)The Inland Revenue may make provision by regulations for the purposes of this Part of this Schedule for the resolution of disputes as to whether a document, or part of a document, is an item subject to legal privilege.U.K.
(2)The regulations may, in particular, make provision as to—
(a)the custody of the document whilst its status is being decided,
(b)the appointment of an independent, legally qualified person to decide the matter,
(c)the procedures to be followed, and
(d)who is to meet the costs of the proceedings.