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

Michael Jones QC is a highly respected new silk experienced in a broad range of tax issues, who has a focus on corporate and commercial matters, including shareholder taxation and employment tax issues. He is regularly instructed in high-value litigation both for the taxpayer and for HMRC. “Very affable, intelligent and collegiate.” “He is incredibly thorough and has a high knowledge and command of all corners of the tax system.”

Tax – Chambers and Partners 2022

Michael Jones QC receives strong praise from peers for his handling of indirect tax matters. He represents both the Revenue and the taxpayer in noteworthy cases involving VAT and stamp duty.

“Very sound and technically very accomplished.” “He has a very pleasant demeanour and knows his stuff inside out.”

Tax: Indirect – Chambers and Partners 2022

Michael 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 has appeared in a number of the most high-value and interesting tax cases in recent years, including several in the Supreme Court and the CJEU, acting both for taxpayers and for HM Revenue and Customs. Before taking silk, he was a member of the Attorney General’s A Panel of junior counsel, appointed to conduct the most complex government cases in all kinds of courts and tribunals.

Michael’s extensive litigation and disputes experience covers all kinds of tax and tax-related matters, from tribunal appeals and judicial review to civil claims and arbitration, and he has appeared at all levels from the Supreme Court to the County Court.

A significant part of his practice involves advising and acting in relation to commercial disputes and restitutionary claims that have a tax angle and he has been involved in a number of the leading cases in this area.

He covers the full spectrum of UK tax law, but with a particular 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 work (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
  • capital allowances
  • tax aspects of distressed M&A, insolvency and restructuring
  • the taxation of 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 other jurisdictions, in particular Hong Kong, Singapore, the Turks and Caicos Islands and Bermuda.

Education:
  • LLB (Hons) (1st Class), BCL (Oxon) (Distinction)
Recent reported cases include:
  • Gunfleet Sands Limited, Gunfleet Sands II Limited, Walney (UK) Offshore Windfarms Limited, Orsted West of Dudden Sands (UK) Limited v Revenue & Customs [2022] UKFTT 35 (TC)
  • Mark Dunsby v Revenue and Customs [2021] UKUT 289 (TCC)
  • Tinkler v Revenue and Customs [2021] UKSC 39
  • Tower Bridge GP Limited v Revenue and Customs [2021] UKUT 30 (TCC)
  • Clipperton & Anor v Revenue & Customs [2021] UKFTT 12 (TC)
  • Cobalt Data Centre 2 LLP Cobalt Data Centre 3 LLP v Revenue and Customs [2020] UKUT 356 (TCC)
  • Total E&P North Sea UK Ltd & Anor v Revenue And Customs [2020] EWCA Civ 1419
  • Charman v Revenue and Customs [2020] UKUT 253 (TCC)
  • Axa S.A. v Genworth Financial International Holdings, Llc & Ors [2020] EWHC 2024 (Comm)
  • Dunsby v Revenue & Customs [2020] UKFTT 271 (TC)
  • Clark v HM Revenue and Customs [2020] EWCA Civ 204
  • Cobalt Data Centre 2 LLP and Cobalt Data Centre 3 LLP v Revenue and Customs [2019] UKUT 342 (TCC)
  • Tinkler v Revenue & Customs [2019] EWCA Civ 1392
  • Ingenious Games LLP and Others and Revenue and Customs [2019] UKUT 226 (TCC)
  • Jazztel Plc v HM Revenue and Customs [2019] EWCA Civ 1301
  • Martin & Ors v Harris [2019] EWHC 1962 (Ch)
  • Revenue and Customs v Total E&P North Sea UK Ltd and Total Oil UK Ltd [2019] UKUT 133 (TCC)
  • Tower Bridge GP Ltd v Revenue & Customs [2019] UKFTT 176 (TC)
  • Jupiter Asset Management Group Ltd v Revenue & Customs [2019] UKFTT 56 (TC)
  • Charman v Revenue & Customs [2018] UKFTT 765 (TC)
  • Clark v Revenue and Customs [2018] UKUT 397 (TCC)
  • Vacation Rentals (UK), R. (On application of) v Revenue and Customs (Tax) [2018] UKUT 383 (TCC)
  • The Serpentine Trust Ltd v Revenue & Customs [2018] UKFTT 535 (TC)
  • Jazztel Plc v Revenue And Customs [2018] EWHC 1830 (Ch)
  • JDI International Leasing Ltd v The Commissioners for HM Revenue and Customs [2018] UKUT 214 (TCC)
  • Tinkler v The Commissioners for HM Revenue and Customs [2018] UKUT 73 (TCC)
  • Revenue and Customs v NT ADA Ltd (formerly NT Jersey Ltd) [2018] UKUT 59 (TCC)
  • Vaines v HM Revenue and Customs [2018] EWCA Civ 45
  • Maersk Oil North Sea UK Limited and Maersk Oil UK Limited v The Commissioners for HMRC [2018] UKFTT 20.
  • United Biscuits (Pension Trustees) Ltd & Anor v Revenue And Customs [2017] EWHC 2895 (Ch)
  • Towers Watson Ltd v Revenue & Customs [2017] UKFTT 846 (TC)
  • Littlewoods Ltd and others v Commissioners for Her Majesty’s Revenue and Customs [2017] UKSC 70
  • 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