The taxman has allegedly been given new powers to seize documents from taxpayers that could be legally privileged, in a move that forms part of new dispute resolution rules. In April HM Revenue & Customs gained the power to carry out site inspections at businesses, and it now has the power to seize the disputed documents, which are placed in a sealed container that HMRC takes custody of until the dispute is referred to the Tax Tribunal for resolution, according to law firm McGrigors. 'HMRC has never liked the fact that the advice taxpayers have taken from barristers and other lawyers may be protected by legal professional privilege, and they routinely mount an aggressive challenge over how far the privilege extends,' said Jason Collins, partner in tax litigation at law firm McGrigors. 'Until now there has never been a statutory procedure for resolving disputes over whether documents are subject to legal professional privilege. The system which has been put in place is unfairly weighted in HMRC's favour and will result in many more confidential documents being subjected to scrutiny,' he added. Collins claims that the new rules are part of the taxman's 'ongoing clampdown against legitimate tax planning'. 'It wants to get access to the advice that taxpayers are getting from their professional advisers in order to scupper any tax planning schemes before they get off the planning table,' he said. But this was disputed by HMRC, which said there was no obligation involved. A spokesman told Accountancy: 'It's wholly wrong to suggest that HMRC has a new power to seize disputed documents. There is no erosion of LPP in the new regulations. There will be a new disputes resolution procedure which is intended to make it easier for all parties. 'The new law introduced this April clearly sets out that privileged information is protected. If, however, both sides agree that a document is in dispute it can be put in a sealed container and delivered to the Tribunal. HMRC officers cannot oblige the taxpayer to provide the document. It is completely incorrect to suggest otherwise.'