Jeremy Woolf

Called: 1986

Jeremy Woolf

Jeremy Woolf’s practice includes a mixture of non-contentious and contentious work relating to all taxes, including personal and corporate taxes, VAT and SDLT. Contentious work includes negligence, judicial review and variation of trust act and rectification proceedings raising tax issues.

Jeremy is qualified to accept Public Access instructions.

  • Career

    Called 1986

  • Education

    University of Sussex BA (Upper Second)

    Cambridge University LLM (Upper Second)

  • Publications

    Zamir and Woolf: The Declaratory Judgment (2nd, 3rd and 4th Edition)

    DeSmith Woolf & Jowell: Judicial Review of Administrative Action 5th Edition (contributor of Chapter 23 on Revenue Law)

    Halsbury’s Laws of England Vol 12(2) Customs and Excise (joint contributor)

    DeVoil Indirect Tax Service (contributor)

    Simon’s Direct Tax Service (contributor)

    Civil Appeals (contributor to chapter on tax appeals)

    Potter & Monroe – contributor

  • Significant cases

    VAT:

    Abbey National -v- Commissioners of Customs and Excise [2006] STC 1136 (European Court of Justice): the scope of the exemption in Article 13B(d)(6) of the Sixth Directive for the management of special investment funds

    My Travel plc (formerly Airtours plc) -v- Commissioners of Customs and Excise [2005] STC 1617: (European Court of Justice): tour operator’s margin scheme and apportionment of consideration

    Commissioners of Customs and Excise -v- Pegasus Birds [2004] STC 1509 (CA) validity of best judgment assessment

    Customs and Excise -v- Madgett & Baldwin [1998] STC 1189 (European Court of Justice): tour operator’s margin scheme and apportionment of consideration

    Computeach International Limited [1994] VATTR 237: unjust enrichment

    DenmanCollege [1998] VATDR 399: supplies of construction and services

    Oxford, Swindon & Gloucester Co-op -v- Customs and Excise [1995] STC 5283: retail schemes

    Investigations and human rights

    King -v- Walden [2001] STC 822: whether civil penalties are criminal for Human Rights purposes and issue estoppel on tax appeals

    King -v- United Kingdom [2004] STC 911 application to the European Court of Human Rights: whether civil penalties are criminal and whether delay resulted in a breach of article 6 of the Convention

    R (on the application of APVCO 19 Ltd) v HM Treasury [2015] STC 2272 (CA) (compatibility of retrospective legislation with the European Court of Human Rights)

    Income tax, capital gains tax, corporation tax, stamp duty and national insurance:

    Dunsten -v- Young Austen & Young [1989] STC 69: meaning of reorganisation

    CIR -v- Burton [1990] STC 242: approval of share scheme

    Pepper -v- Hart [1993] STC 898 HL: use of Hansard/benefits in kind

    Marriot -v- Lane [1996] STC 704: retirement relief

    Edmunds -v- Coleman [1997] STC 1406: new profession

    R -v- IRC ex p Roux [1997] STC 781: removal of approval from pension scheme

    HMRC -v- Household Estates [2007] EWHC 1684 (ch): power to make further assessments

    Talentcore -v-HMRC [2012] UKUT 423 (TCC): agency workers

    John Mander Pension Trustees Ltd v HMRC  [2015] STC 2231 (SC) (validity of assessment made on retrospective loss of approval of a pension scheme)

    Inheritance tax:

    IRC -v- Eversden [2003] STC 822 (CA): reservation of benefit on spouse exempt gifts

  • Memberships

    Revenue Bar Association

    CIOT indirect tax sub-committee

    Chairman: CIOT EU and Human Rights sub-committee

    Chair of the indirect tax sub-committee and vice chair of the fiscal committee of the Confederation Fiscale Européenne

    The Confederation Fiscale Européenne’s alternate representative on the European Commission’s VAT Expert Group

    The CIOT’s alternate representative on the European Commission’s Expert Group on removing tax problems facing individuals who are active across borders within the EU

    VAT Practitioners Group

    London Common Law & Commercial Bar Association

    Chancery Bar Association

    Institute of Indirect Taxation (Fellow)

    Stamp Taxes Practitioners Group

    Administrative Law Bar Association

  • Awards

    Award of Certificate of Merit (Chartered Institute of Taxation)

  • The Chambers Guide says...

    Tax: Corporate
    Ranking: Band 1

    Senior junior with extensive experience in a range of complex corporate tax litigation and advisory mandates. He is particularly strong on income tax and employee benefit trusts issues. He is also knowledgeable about judicial reviews and tax-related human rights matters.
    “Very thorough.” “Technically strong and very user-friendly.” (2019)

    . . . “He has a detailed knowledge of tax law and an ability to size up a situation and deliver relevant, pertinent advice.” “Very user-friendly.” (2018)

    . . . ”He is very client-friendly, almost impossibly nice and charming, and very tenacious. He will pull out all the stops and will work frighteningly hard to win.” (2017)

  • The Legal 500 says...

    Tax: VAT
    Ranking: Leading Junior, Tier 3

    ‘He is admired for his knowledge of international tax issues.’ (2018)

    ‘Strikes a good rapport with judges and an absolute delight to work with.’ (2017)

    ‘He always impresses with his sound, erudite, no-nonsense advocacy’ (2016)

    Tax: Corporate
    Ranking: Leading Junior, Tier 1

    ‘He is an absolute delight to work with.’ (2018)

    ‘Confident even in the most challenging court situations.’ (2017)

    ‘A softly spoken yet heavyweight advocate’ (2016)

    Tax- Private Client: Personal Tax
    Ranking: Leading Junior, Tier 3

    ‘Highly rated for SDLT.’ (2018)

    ‘Exceedingly strong; he cannot be recommended highly enough.’ (2017)

    ‘He provides practical and helpful advice on international personal tax matters.’ (2016)

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