36 Queen Street, London, EC4R 1BN
+44 (0)20 7242 2642
Michael Jones
Michael Jones

was called to the Bar in 2006, having obtained a distinction on the BCL at Oxford University and a first-class law degree at the University of Nottingham. He won a number of academic prizes, including for tax law, and was awarded Hardwicke, Denning and Megarry Scholarships by Lincoln’s Inn. At Bar School he came top of his year, winning the Taylor and Buchanan Prizes.

Michael’s practice involves an even mix of advisory and litigation work and he is instructed to advise and represent in court both taxpayers and HM Revenue and Customs. In 2010 he was appointed by the Attorney General as Junior Counsel to the Crown (C Panel). He is recommended as a tax junior in Chambers and Partners.

The advisory side his practice covers the full spectrum of UK tax law but with a focus on all aspects of corporate and commercial tax and VAT work, including:

  • the taxation of corporate finance (particularly loan relationships and derivatives)
  • M&A (especially transaction structuring, tax deeds and warranties)
  • shareholder taxation
  • employment tax (including share schemes and EBTs)
  • company reorganisations and reconstructions
  • debt restructuring (including the tax treatment of debt-for-equity swaps, debt buy-backs and subordination)
  • property taxation and SDLT
  • tax aspects of “distressed M&A”, insolvency and restructuring
  • the taxation of alternative investment funds, including private equity funds, hedge funds and property investment funds
  • the tax treatment of trusts in a commercial context

In addition to advising on UK taxes, Michael has experience of advising on the tax laws of Hong Kong, Singapore and the Turks and Caicos Islands.

On the litigation side Michael is regularly instructed to act for both taxpayers and HMRC in relation to tax appeals, disputes and investigations across all areas of tax law, including direct tax, VAT and customs and excise matters, and has appeared in County Courts, the Tax Tribunals, the High Court, the Court of Appeal, the Privy Council and the CJEU.

He also has extensive experience of judicial review claims and other tax-related actions (including restitutionary claims against HMRC, enforcement proceedings and tax deed disputes).  His recent experience in these areas include:

  • Acting for the claimant in judicial review proceedings against HMRC in respect of the legality of their attempt to set-off a VAT credit against a self-assessment debt – R (oao Rouse) v HMRC
  • Acting for the claimants in the Littlewoods compound interest litigation currently before the High Court.
  • Acting for the claimant in a tax deed dispute concerning losses within a target company.
  • Acting for the claimant in a dispute (involving contractual and restitutionary claims) following an unsuccessful structured finance tax transaction.

In addition to appearing in court, Michael is frequently involved in settling pleadings, advising on evidence and providing advice on litigation strategy.


Recent cases include:

Degorce v HMRC [2017] EWCA Civ 1427

W Nagel (A Firm) v Pluczenik Diamond Company NV [2017] EWHC 2104 (Comm)

OCO Ltd and Toughglaze (UK) Ltd v Revenue and Customs [2017] UKFTT 589 (TC)

HMRC v Brockenhurst College (Case C-699/15) (CJEU) (2017)

BNP Paribas SA (London Branch) v Revenue and Customs [2017] UKFTT 487 (TC)

Ingenious Games& Ors v Revenue and Customs [2017] UKFTT 429 (TC)

Gareth Clark v Revenue and Customs [2017] UKFTT 392 (TC)

Revenue and Customs v Boyce (t/a Glenwood) [2017] UKUT 177 (TCC)

JDL International Leasing Ltd v Revenue and Customs [2017] UKFTT 329 (TC)

Revenue and Customs v The Investment Trust Companies [2017] UKSC 29

Blackwell v HM Revenue & Customs [2017] EWCA Civ 232

Volkswagen Financial Services (UK) Ltd v Revenue and Customs [2017] UKSC 26

Jazztel Plc v Revenue and Customs [2017] EWHC 677 (Ch)

Lyle and Scott Ltd & Ors v Revenue and Customs [2017] UKFTT 137 (TC)

Finmeccanica Global Services Spa v HM Revenue and Customs [2016] EWCA Civ 1105

NT ADA Ltd (formerly NT Jersey Ltd) v Revenue and Customs [2016] UKFTT 642 (TC)

Clark v Revenue and Customs [2016] UKFTT 630 (TC)

Longridge On the Thames v Revenue and Customs [2016] EWCA Civ 930

Degorce v Revenue and Customs [2016] UKFTT 429 (TC)

Peninsular & Oriental Steam Navigation Company v HM Revenue and Customs [2016] EWCA Civ 468

Shop Direct Group v Revenue and Customs [2016] UKSC 7

Tower Bridge GP Ltd v Revenue and Customs [2016] UKFTT 54 (TC)

HM Revenue and Customs v Brockenhurst College [2015] EWCA Civ 1196

Volkswagen Financial Services (UK) Ltd v HM Revenue & Customs [2015] EWCA Civ 832

Peninsular & Oriental Steam Navigation Co. v Revenue And Customs [2015] UKUT 312 (TCC)

Littlewoods Ltd & Ors v HM Revenue and Customs [2015] EWCA Civ 515

Investment Trust Companies v Revenue and Customs [2015] EWCA Civ 82


Qualifications

LLB (Hons) (1st Class), BCL (Oxon) (Distinction)