Expert Witness Journal Issue 63 October 2025 - Flipbook - Page 60
are given responsibility for obtaining legal advice.
Documents produced by other employees may not
be protected by LPP, even if the documents were
prepared for the purpose of enabling legal advice
to be given. As a practical matter, it is important to
de昀椀ne the “client” group at the outset and maintain
and update a record of that group through the
enquiry. Note that too wide a “client” group may be
deemed arti昀椀cial and could risk a waiver of privilege,
while too narrow may give rise to practical issues for
the purposes of providing lawyers with instructions.
Bonus: how we can help!
Please get in touch with any of us or another member
of Slaughter and May’s market-leading tax disputes
team3 if you have any questions on the topics
discussed in this blog or another tax disputes query.
We have extensive experience in advising at every
stage of a wide range of disputes from questions
of UK corporation tax, partnership taxation and
VAT grouping to treaty interpretation and transfer
pricing. Whether you are looking for strategic
advice in respect of an ongoing issue or proactive
risk management through the creation of defence
昀椀les or an audit of existing processes, we can help.
Are the rules on privilege the same across
di昀昀erent jurisdictions?
No. The rules can vary between di昀昀erent jurisdictions.
One di昀昀erence between English and EU law is, for
instance, that, under English law, privilege covers
advice by inhouse lawyers and lawyers quali昀椀ed
abroad. In contrast, EU law recognises privilege only
in respect of advice by external counsel quali昀椀ed in
an EEA country. There are also di昀昀erences between
privilege in the UK and the US. Under English
law, it is possible to share selected documents for
a limited purpose without losing privilege. This is
referred to as “limited waiver”. As that concept is not
recognised in the US, the IRS would likely consider
any applicable US privilege to have been lost where a
document is shared with HMRC (even if on a limited
waiver basis).
References
1
Previously shared blog
https://www.europeantax.blog/post/102l45f/how-to-respondto-information-requests-from-hmrc
2
Tax disputes in UK series
https://www.europeantax.blog/tag/tax%20disputes%20
series%202025
3
Slaughter and May’s market-leading tax disputes team
https://www.slaughterandmay.com/services/practices/tax/
tax-disputes
Dr Nader Khandanpour
Consultant Neuroradiologist - MD, PhD, FRCR, CUBS, EDINR
Dr Nader Khandanpour is a radiology consultant, subspecialising in neuroradiology, based at St George's
University Hospital, London.
Accredited Mediator: CEDR, Centre of Effective Dispute
Resolution, London.
Expertise includes:
Neuroradiology (Brain and Spine CT & MRI)
Neonatal - Paediatrics - Adults
Brain related expertise includes:
Non Accidental Head Injury
Vertigo/Dizziness
Cerebral palsy
Physiotherapy Rehab
Seizures/Epilepsy
Memory loss
Normal pressure hydrocephalus
Muscular dystrophy
Neuromuscular and related diseases,
Movement Disorders
Neuroradiology imaging, MRI & CT scan
Cardiff University Bond Solon Accreditation: CUBS Civil,
Criminal & Family Expert Witness.
Winner of The Expert Witness Awards - London, UK, Lawyer Monthly Magazine (2019)
Alzheimer’s & other Dementias
Stroke/Cerebrovascular Disease
Brain injury
Brain tumour
Concussion
Dementia
A&E Medicine
Mental Health
Numbness
Tremor
Seizures
Bell’s palsy
Headache
Multiple sclerosis
Neuralgia
Neuropathy
Parkinson’s disease
Scoliosis
Neurodegeneration
Infection Radiology imaging
Psychiatric conditions (severe depression, obsessive-compulsive disorder)
Spinal expertise includes:
Trauma
Spinal trauma
Birth defects of the brain & spinal cord
Disk disease of neck & lower back
Spinal deformity/malformation
Spine tumour
Peripheral neuropathy, myasthenia gravis & neuromuscular disorders
Back pain
Spinal cord injury
Pain
Instructions on behalf of:
Claimant , Defendant and Joint
Mobile: 07570 187387 - Email: DrNader@eSupraLife.com - Web: drkhandanpur.com
St George's Hospital, Blackshaw Road, Tooting, London, SW17 0QT - Area of work: National (UK) & International
EXPERT WITNESS JOURNAL
58
OCTOBER/NOVEMBER 2025
