8(1)Subject to paragraphs 9 and 10 below, a notice under subsection (3) or subsection (5)—
(a)does not oblige a person who has been appointed as an auditor for the purposes of any enactment to deliver or make available documents which are his property and were created by him or on his behalf for or in connection with the performance of his functions under that enactment; and
(b)does not oblige a tax adviser to deliver or make available documents which are his property and consist of relevant communications.
(2)In sub-paragraph (1) above “relevant communications” means communications between the tax adviser and—
(a)a person in relation to whose tax affairs he has been appointed, or
(b)any other tax adviser of such a person,
the purpose of which is the giving or obtaining of advice about any of those tax affairs; and in this paragraph “tax adviser” means a person appointed to give advice about the tax affairs of another person (whether appointed directly by that other person or by another tax adviser of his).