External legal opinion on DTA scheme

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| |Freedom of Information & |
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| |Data Protection Act Team |
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| |Room 1C/25 |
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| |100 Parliament Street |
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| |London |
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| |SW1A 2BQ |
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| |Mr N Jagger |Tel 020 7147 0406 |
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| |By email |Fax 020 7147 0666 |
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| | |www.hmrc.gov.uk |
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| | Date |16 February 2010 | |
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| |Our Ref |FOI 1189 /10 | |
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| |Your Ref | | |
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|Dear Mr Jagger | |
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Freedom of Information Act 2000

Thank you for your e-mail of 15 February 2010 regarding external counsel
legal opinion of BN66 . Your request was received at HMRC on 15 February
2010 and I am dealing with it under the terms of the Freedom of
Information Act 2000.

HMRC will provide information in response to a request free of
charge. However, HMRC may ask you to pay our costs where there is lot of
information involved, for example replies in excess of 250 sheets of
photocopying. Whenever we contemplate charging we will provide full
details of the charges and payment will be required before we send the
response.

If you have any queries about this letter, please contact me. Please
remember to quote the reference number above in any future communications.

Yours faithfully

Tony High

Freedom of Information Act Team

The information in this e-mail and any attachments is confidential and may
be subject to legal professional privilege. Unless you are the intended
recipient or his/her representative you are not authorised to, and must
not, read, copy, distribute, use or retain this message or any part of it.
If you are not the intended recipient, please notify the sender
immediately.

HM Revenue & Customs computer systems will be monitored and communications
carried on them recorded, to secure the effective operation of the system
and for lawful purposes.

The Commissioners for HM Revenue and Customs are not liable for any
personal views of the sender.

This e-mail may have been intercepted and its information altered.

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Communications via the GSi may be automatically logged, monitored and/or
recorded for legal purposes.

Dear Mr Jagger,

I apologise for the delay but I now attach HMRC's reply to your request
for information about the date of legal advice.

Yours sincerely

John Sharpe
HMRC FOI Policy Team
Central Policy
Room 1C/25
100 Parliament Street
London
SW1A 2BQ

fax 020 7147 0666
e-mail [email address]

The information in this e-mail and any attachments is confidential and may
be subject to legal professional privilege. Unless you are the intended
recipient or his/her representative you are not authorised to, and must
not, read, copy, distribute, use or retain this message or any part of it.
If you are not the intended recipient, please notify the sender
immediately.

HM Revenue & Customs computer systems will be monitored and communications
carried on them recorded, to secure the effective operation of the system
and for lawful purposes.

The Commissioners for HM Revenue and Customs are not liable for any
personal views of the sender.

This e-mail may have been intercepted and its information altered.

show quoted sections

Communications via the GSi may be automatically logged, monitored and/or
recorded for legal purposes.

Dear Mr Jagger
With apologies for the oversight I attach HMRC's response to your
request for review.

Yours sincerely,

Margaret Earing
HMRC Freedom of Information Team
Central Policy Information Strategy
100 Parliament Street
Westminster
London SW!A 2BQ

020 7147 0233 Tuesday, Wednesday & Friday

The information in this e-mail and any attachments is confidential and may be subject to legal professional privilege. Unless you are the intended recipient or his/her representative you are not authorised to, and must not, read, copy, distribute, use or retain this message or any part of it. If you are not the intended recipient, please notify the sender immediately.

HM Revenue & Customs computer systems will be monitored and communications carried on them recorded, to secure the effective operation of the system and for lawful purposes.

The Commissioners for HM Revenue and Customs are not liable for any personal views of the sender.

This e-mail may have been intercepted and its information altered.

show quoted sections