Download CV as PDFJonathan practises in all areas of tax law. He advises on the major UK taxes and acts in tax appeals and tax-related litigation before the specialist tribunals and the higher courts.
He is happy to accept instructions under the Joint Advisory Scheme and Special Advocacy Scheme .
Areas of practice
Examples of recent cases include:
Business/Corporate Tax
Acting (with Graham Aaronson QC and James Henderson) for a multinational group of pharmaceutical companies in a very substantial dispute concerning the application of the UK transfer pricing and CFC rules.
Acting in disputes concerning employee remuneration structures established by a variety of companies including a leading City metal trading company (see Sempra Metals Ltd v HMRC [2008] STC (SCD) 1062), a hedge fund and a major football club.
Acting in judicial review proceedings brought on behalf of a major property investment fund.
Acting and advising in relation to issues concerning HMRC enquiries, including applications for closure notices (see, for example, Vaccine Research LLP v HMRC [2009] UKFTT 333 (TC)).
VAT
Input tax recovery issues (see, for example, Camden Motors Ltd v HMRC [2008] UKVAT V20674 (standard method override); HMRC v London Clubs Management Limited (Upper Tribunal, June 2010) (special method based on floor space); Airtours Holidays Transport Ltd v HMRC [2009] UKFTT 256 (TC) (scope and application of the Redrow principle)).
The scope and application of exemptions from VAT (see, for example, Barclays Bank Plc v HMRC [2008] UKVAT V20528 (financial services/debt collecting); British Association for Shooting and Conservation v HMRC (First-tier Tribunal, June 2010) (sporting exemption)) and of the zero rate (see, for example, West Country Vending Ltd v HMRC [2010] UKFTT 124 (TC)).
Bad debt relief and the validity of credit notes (Brunel Motor Co Ltd v HMRC [2009] STC 1146 (CA)).
Claims to recover overpaid VAT (see, for example, Midlands Co-operative Society v HMRC [2008] STC 1803 (CA)).
Abuse of rights issues (see, for example, Moorbury Limited v HMRC [2009] UKFTT 180 (TC) and UT (FTC), June 2010).
Personal Tax
Acting for the taxpayer in a substantial dispute concerning claims for loss relief for income tax purposes.
Acting and advising in relation to a dispute concerning the availability of relief under the Enterprise Investment Scheme.
Acting and advising in relation to HMRC enquiries, including applications for closure notices.
Recent advisory work
Business/Corporate Tax
Transfer pricing issues (including group treasury arrangements and intra-group management charges).
Employee remuneration structures.
Company reconstructions (including clearance applications).
VAT
Partial exemption issues.
Remedies against HMRC and against contractual counterparties in respect of overpaid VAT.
Issues concerning the application of the capping legislation.
Personal tax
Trust taxation issues.
Reservation of benefit and POAT issues.
Insurance policies.
Land development projects.
Tax issues concerning the family home.
Entrepreneurs’ relief.
Career
Called: 2005 (Inner Temple)
Significant cases
Barclays Bank Plc v HMRC (VAT Tribunal)
Camden Motors (Holdings) Ltd v HMRC (VAT Tribunal)
Midlands Co-operative Society Ltd v HMRC (Court of Appeal)
Sempra Metals Ltd v McDonald (HMIT) (Special Commissioners)
Brunel Motor Company Ltd v HMRC (Court of Appeal)
Airtours Holidays Transport Ltd v HMRC (FTT (TC))
West Country Vending Ltd v HMRC (FTT (TC))
British Association for Shooting and Conservation v HMRC (FTT (TC))
Moorbury Ltd v HMRC (UT (FTC))
HMRC v London Clubs Management Limited (UT (FTC))
Publications
Jonathan is a contributor to Potter and Monroe's Tax Planning with Precedents. He regularly contributes articles to specialist tax journals and gives lectures on tax.
Memberships
Revenue Bar Association
VAT Practitioners Group
Education
Hertford College, University of Oxford - BA (First Class), BCL (Distinction)
University of Paris II (Panthéon-Assas) - Certificat Supérieur de Droit Français (Mention Bien)
BPP Law School - Bar Vocational Course (Very Competent)
Languages
French (fluent, including technical legal French)
Other experience
Before joining Chambers, Jonathan undertook twelve months' pupillage at leading commercial set One Essex Court.
In 2007, he was seconded for six months to the tax department of Farrer & Co LLP where he advised on the tax aspects of a broad range of corporate, property and private client matters.
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