Tax Disclosure / Compliance Request


A Guernsey company was served with a notice to disclose all its working files (including both internal and external email correspondence) to an overseas tax authority, as part of an investigation into the affairs of the beneficial owners of that company. The company’s administrator was given a set period in which to compile and present all requested files.


KRyS Global was retained on an urgent basis to assist the company’s administrator to comply with the disclosure order, which included provision of the internal and external email correspondence relating to the company within a certain period but without disclosing correspondence (or documents) that were subject to legal professional privilege.
After swiftly extracting the data from the administrator’s servers, KRyS Global’s forensics team undertook a capture of all data in relevant staff members’ mailboxes to segregate all correspondence that may relate to the company. The team then quickly identified the relevant correspondence that would not be subject to privilege through a combination of keyword searches and filtering of correspondence with certain parties.
The team also used software to ‘de-thread’ and ‘de-duplicate’ email chains to simplify the review process being undertaken by the administrator’s document review team.

Value Added:

Ultimately, the KRyS Global forensics team reduced a population of approximately 20,000 emails relating to the company over a period of several years to a set of approximately 200 emails that required individual review by the administrator in order to determine whether they would be subject to legal privilege. The team also then compiled the disclosure / presentation of the documents to comply with the disclosure request.