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Jonathan Davey QC

Call: 2003    QC: 2016

+44 (0)20 7306 0102jdavey@wilberforce.co.uk

Trusts, Tax, Probate & Estates

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

He is recommended in Chambers & Partners as a leading private client / personal tax practitioner who is involved in “numerous high value private client matters” and is praised for his ability to “handle complex litigation matters with aplomb”.

He is recommended in The Legal 500 (in both the private client tax and general tax categories) as a “key figure” who has considerable experience of large scale and high value litigation in the area.

Jonathan is currently involved in two of the largest, most complex and highest profile pieces of tax litigation ever to be dealt with by the UK courts. The Ingenious and Icebreaker proceedings, both of which involving financial structures related to the creative industries, are regularly the national press, the latter under the headline “Taxman vs Take That”.

Jonathan is also recommended in Chambers Global in the field of private wealth.

Some representative cases include:

  • The Estate of Lady Hood v Commissioners for HMRC [2018] EWCA Civ 2405: Acting successfully for the Respondents in this important inheritance tax dispute, which was significant in testing the scope of a number of key House of Lords and Court of Appeal decisions in this area.
  • Charity Commission v Mounstar and others [2016] EWHC 876 (Ch): Dispute in respect of charity involved in £45m tax avoidance scheme.
  • Ingenious and Others v HMRC [2015]: £1bn dispute regarding proper commercial and tax analysis to apply in respect of partnerships involved in the film and games industries (with Malcolm Gammie QC).
  • Freedman v Freedman [2015] EWHC 1457 (Ch): Dispute in respect of doctrine of equitable mistake in relation to tax planning and family trust.
  • Icebreaker and Others v HMRC [2014] UKFTT 416 (TC): £400m dispute regarding proper commercial and tax treatment of limited liability partnerships involved in the creative industries.
  • Hanson v HMRC [2013] UKUT 224 (TCC): Inheritance tax dispute in respect of proper analysis to apply in relation to rural estate.
  • Atkinson v HMRC [2012] UKUT 506 (TCC): Inheritance tax dispute in respect of agricultural property relief.
  • Acting for trust protector in multi-party breach of trust claim in respect of Gibraltar based trusts (with Christopher Nugee QC).
  • Acting for the defendants in Cayman-based Re Jahre litigation involving claims for US$250m alleged to belong to a Norwegian shipping tycoon. Case described in The Independent as “truly epic litigation” of “mind-numbing complexity” (with Camilla Bingham).