Jonathan Levy
- Tel:
- Work +44 20 7760 4452
- Email:
Work Department
Corporate tax.
Position
Advises corporate groups and high-net-worth individuals on how best to minimise the likelihood of disputes with Her Majesty’s Revenue & Customs, and assists them with settlements and litigation. Has conducted high-profile cases before the tax tribunals appearing as advocate against both leading and junior counsel, High Court, Court of Appeal and the House of Lords. Notable cases include Elf Enterprise Caledonia Ltd & ors v IRC [1994] CHD 785; Chevron UK Ltd v IRC [1995] STC 712; Steele (HMIT) v European Vinyls Corp (Holdings) BV [1996] CA 785; Memec Plc v IRC [1998] CA 754; Unigate Overseas Ltd v McGregor [1998] STC (SCD) 1; Pirelli Cable Holding NV v IRC [2003] STC 250; New Angel Court Ltd v Adam [2004] EWCA Civ 242; and Dextra Accessories & ors v MacDonald (HMIT) [2005] UKHL 47. Acting in two of the largest cases in the UK concerning the tax treatment of film partnerships that is currently an area of major controversy with HMRC. One matter concerns trade losses for over £100m claimed by four film partnerships dealing in the trade of developing and pre-producing feature films. The other matter concerns over 450 high-net-worth investors claiming film losses in excess of £450m.
Career
Career: Trained Hills Solicitors; qualified 1990; senior legal officer, Office of the Solicitor of the Inland Revenue 1990-2000; head of tax litigation, Ernst & Young 2000-03; partner LevyWatters 2003-07; partner Berwin Leighton Paisner 2008. Contributor to ‘Simon’s Direct Taxes’.
Education
Education: Southampton University (1986 LLB Hons); College of Law, Chancery Lane (1988).
Practice Areas
Tax - corporate
