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Jonathan Davey QC

Call: 2003    QC: 2016

+44 (0)20 7306

Trusts, Tax, Probate & Estates

Jonathan is highly experienced and respected across the fields of trusts, tax litigation, probate and estates.

Jonathan is ranked in the legal directories (Chambers UK, Chambers Global and/or The Legal 500) in the areas of trusts – private client; chancery – traditional; tax – direct and indirect; private wealth.

Comments that have been made of him in the most recent directories include:

“A brilliant advocate, excellent with clients, diligent, a leader who will go the extra mile for a client and then some.” (Trusts: Private Client – The Legal 500 2020)

“A thoroughly modern QC who gives very straightforward and to-the-point advice. He’s someone who always provides answers rather than creates problems.” (Tax – Chambers UK 2020)

“He is responsive, thoughtful and open-minded. He listens to the client and is very collaborative in his approach.” (Chancery: Traditional – Chambers UK 2020)

“A very, very good and extremely eloquent advocate.” “Extremely good at explaining things in terms that a non-specialist can understand. He responds very quickly, which is welcome.” (Tax: Private Client – Chambers UK 2020)

Some representative cases include:

  • Ingenious Film Partners 2 LLP v HMRC [2019] UKUT 0226 (TCC) – £1.6 billion dispute concerning taxation of creative industry business structure
  • Clark v HMRC [2019-2020] (Court of Appeal hearing listed for early 2020); [2018] UKUT 397 (TCC) – dispute concerning offshore trust structure used to liberate pension funds
  • Estate of Lady Hood v HMRC [2018] EWCA Civ 2405 – leading Court of Appeal case on estate planning in relation to the family home and the gift with reservation IHT provisions
  • Andrew v HMRC [2019] FTT 177 (TC) – dispute in relation to complex gilt strip trust structure and applicable taxation
  • Shelford v HMRC [2019-2020] (Test case – judgment awaited from the First-tier Tribunal (Tax Chamber)) – dispute concerning inheritance tax home loan arrangements
  • Life Services Ltd v HMRC [2019-2020] (Court of Appeal hearing listed for early 2020) [2019] UKUT 0002 (TC) – dispute concerning relationship between EU principle of fiscal neutrality and UK devolved legislative structure
  • London Luton BPRA Property Fund LLP v HMRC [2019] UKFTT 212 (TC) – multi-million pound capital allowances test case regarding hotel development
  • Seven Individuals v HMRC [2017] UKUT 132 (TCC); Acornwood LLP v HMRC [2016] UKUT 36 (TCC) – £400 million dispute concerning taxation of Icebreaker film scheme
  • Charity Commission v Mounstar [2016] EWHC 876 (Ch) – dispute in respect of charitable trust involved in £45m tax avoidance scheme
  • Freedman v Freedman [2015] EWHC 1457 (Ch) – dispute in respect of doctrine of equitable mistake in relation to a family trust