(1)This section applies where a notice is given under section 258(4) or (5) and the person to whom the notice is given is a tax adviser.
(2)The notice does not require a tax adviser—
(a)to provide information about relevant communications, or
(b)to produce documents which are the tax adviser’s property and consist of relevant communications.
(3)Subsection (2) does not have effect in relation to—
(a)information explaining any information or document which the person to whom the notice is given has, as tax accountant, assisted any person in preparing for, or delivering to, HMRC, or
(b)a document which contains such information.
(4)But subsection (2) is not disapplied by subsection (3) if the information in question has already been provided, or a document containing the information has already been produced, to an officer of Revenue and Customs.
(5)In this section—
“relevant communications” means communications between the tax adviser and—
a person in relation to whose tax affairs the tax adviser has been appointed, or
any other tax adviser of such a person,
the purpose of which is the giving or obtaining of advice about any of those tax affairs, and
“tax adviser” means a person appointed to give advice about the tax affairs of another person (whether appointed directly by that person or by another tax adviser of that person).