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HMRC's argument in the tribunal was that the service was supplied to the solicitor to help in preparing the report on title. Thus, to their thinking, it was not the client using the service, but the solicitor. Paper searches would also have been caught by that argument, but 40 of years of the opposite practice prevents that charge. I would hope the committee would be able to recommend a protocol by which electronic searches can be seen to have identical characteristics to the paper searches, and should be treated the same (eg they are forwarded immediately to the client, and then advice given separately as to what they mean)

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