Joseph Hage Aaronson LLP
UK Guide 2024
Joseph Hage Aaronson LLP
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[email protected]Contact number
(020) 7851 8888Share profile
About
JHA's contentious tax team is led by the renowned Graham Aaronson KC, who has developed a trusted relationship with HMRC (appointed by them to chair the GAAR Interim Advisory Panel), and with the UK Government (appointed by the Treasury to lead the GAAR study, and subsequently by the Prime Minister, David Cameron, in relation to the "Panama Papers" allegations about his family).
Others in the team include Michael Anderson, Paul Farmer, Simon Whitehead, Iain MacWhannell, Richard Doran, Ray McCann, Helen McGhee, Daniel Margolin KC, Lynnette Bober, Steve Bousher, Joe Irwin, Megan Durnford, Grace Webster, John Hayton, Julia Glukhikh and Thomas Hemming. They are supported by in-house barristers, solicitors, pupils, and accountants, combining the best qualities of the bar and a law firm to deliver a cohesive approach to advising and representing clients throughout all stages of a dispute. In some of the most complex and sensitive private client cases we bring in the expertise of Emma Chamberlain OBE, the renowned private client counsel with whom the firm has a close and long-standing relationship.
JHA, being the only law firm in the market which specialises in contentious tax, we remain the firm of choice for the most sensitive, important and high value tax disputes. JHA’s lawyers have experience across all the domestic courts and tribunal system, from the First-tier Tribunal to the Supreme Court. We also represent UK and overseas clients in references to the Court of Justice of the European Union, and in overseas courts in high-value, complex tax disputes.
As is well known, JHA have also been the lead and test-case solicitors in almost all corporation tax Group Litigation Orders (GLOs), which bring together High Court claims made by more than 50 multinational corporations. These are ground-breaking claims that challenge various discriminatory elements of UK tax legislation.
We have particular expertise in relation to COP8 and COP9 HMRC enquiries (and in some cases criminal investigations), where we work proactively with HMRC to achieve the best possible outcome for our clients, while paying the closest attention to preserving their privacy and maintaining confidentiality.
In more recent years, JHA has also built a strong reputation for our tax fraud/abuse and tax investigations work, including our role as lead and test case solicitors in the largest VAT Group Litigation that has ever taken place in the Tax Tribunal.
Our team has acted in many of the most sensitive and highest value disputes of recent years, including those involving novel issues in Transfer Pricing, Diverted Profits Tax, and the compatibility of domestic tax rules with EU state aid rules.
Many of the cases JHA are currently litigating will be at the forefront of the development of law in the post-Brexit environment, especially those disputes that involve the interaction of the Retained EU Law (Revocation and Reform) Act 2023. We continue to run a series of major challenges to tax legislation before the Court of Appeal and Supreme Court as well as acting in proceedings in the European Court and we representing clients in multiple tax-focused civil and criminal investigations.
Where it is essential to do so we will carry a dispute through to litigation to achieve the result which we and the client consider to be the correct application of the tax law to the particular facts. But our preference wherever possible is to seek to persuade HMRC (or the relevant overseas tax authority) that the client’s filing position is correct, or to reach a settlement on the best possible terms.
Notable practitioners
■ Graham Aaronson KC
■ Daniel Margolin KC
■ Michael Anderson
■ Simon Whitehead
■ Iain MacWhannell
■ Paul Farmer
■ Helen McGhee
■ Richard Doran
■ Steve Bousher
■ Emma Chamberlain OBE
■ Ray McCann
■ Lynnette Bober
■ Joe Irwin
■ Megan Durnford
■ Grace Webster
■ John Hayton
■ Julia Glukhikh
■ Thomas Hemming
Ranked Offices
Provided by Joseph Hage Aaronson LLP
- London7th Floor 280 High Holborn , London, Greater London, UK, WC1V 7EE
- Web: uk.jha.com
- Tel: (020) 7851 8888
- View ranked office
Contributions
Latest contributions provided by Joseph Hage Aaronson LLP
Joseph Hage Aaronson LLP rankings
Articles, highlights and press releases
31 items provided by Joseph Hage Aaronson LLP
The End is Nigh for the Non-Dom Regime
Published in ThoughtLeaders4 Private Client Magazine, Helen McGhee expert analysis of the current state of non-dom tax regime and it's future.
On 14 June 2023, HMRC published a substantially rewritten Code of Practice 9 (“COP9”). Helen McGhee and Megan Durnford set out the key changes implemented as a result of this publication.
Pandora Papers: HMRC issues nudge letters
Helen McGhee sets out HMRC's response to the Pandora Papers leak of almost 12 million documents
Increased Investment in Personal Tax Compliance in the UK
Helen McGhee discusses the main developments in support of the increased focus on international transparency and personal tax compliance in the UK.
Tax-Related Measures in the Autumn Statement 2022
This article explores the tax measures included in the Autumn Statement 2022
Offshore Structures and Onward Gifts
This article explores the "onward gift" tax anti-avoidance rules introduced by the Finance Act 2018.
Increased Investment in Personal Tax Compliance in the UK
This article discusses the main developments in support of the increased focus on international transparency and tax compliance in the UK.
Case note: Lynton Exports (Alsager) Ltd v Revenue and Customs Commissioners [2022] UKFTT 00224 (TC)
JHA’s latest insight into the First-tier Tribunal’s decision in Lynton Exports (Alsager) Ltd v Revenue and Customs Commissioners [2022] UKFTT 00224 (TC).
What is domicile and why does it matter for tax?
A quick review of the fundamental principle of domicile, why it matters for tax, and what the current political landscape has in store.
Tax note: Financial Institution Notices (FIN)
Understanding paragraph 4A of Schedule 36 to the Finance Act 2008
FTT Decision on Excise Duty in Cantina Levorato SRL v HMRC [2021] UKFTT 461 (TC)
A Short Case Report on the FTT decision in Cantina Levorato SRL v HMRC [2021] UKFTT 461 (TC)
Fast Track for Register of Overseas Entities Owning UK Property
The invasion of Ukraine has prompted the UK government to speedily publish the draft legislation for the Economic Crime (Transparency and Enforcement) Bill 2022.
Global Minimum Tax on Corporations: OECD GloBE Model Rules and their implementation in the UK
On 8 October 2021, the OECD/G20 published a statement confirming that 136 jurisdictions had agreed to a two-pillar solution to address the tax challenges that arise from the digitalisation of the economy and setting out an implementation plan.
‘MTIC’ Fraud – Kittel Test PTGI International Carrier Service Limited v. HMRC [2022] UKFTT 20 (TC)
A summary of the FTT decision in PTGI International Carrier Service Limited v. HMRC [2022] UKFTT 20 (TC)
HMRC consultation on the OECD mandatory disclosure rules
HMRC has published a consultation on draft regulations to implement the Organisation for Economic Cooperation and Development (OECD) rules on mandatory disclosure of certain avoidance arrangements. Helen McGhee explains the background to the new rules and their implications.
Post-Prudential: Decision released by the FTT
On 8 December 2021, judgment in the Post Prudential Group Litigation was handed down by the First-tier Tribunal (Tax Chamber) (“FTT”).
S&S Consulting Services (UK) Ltd v HMRC: Can a company be re-registered for VAT pending appeal?
On 26 November 2021, the High Court of Justice issued its judgment in S&S Consulting Services (UK) Ltd, R (On the Application Of) v HM Revenue and Customs [2021] EWHC 3174
VAT De-registration: the CJEU decision in the Promexor case
On 18 November 2021, the Court of Justice of the European Union (the “CJEU”) delivered its judgment in Case C-385/20 (Promexor Trade SRL v Directia Generala a Finantelor Publice Cluj – Administratia Judeteana a Finantelor Publice Bihor).
Helen McGhee discusses the use of corporate vehicles in family wealth and succession planning in the UK
Helen McGhee considers the Court of Appeal’s judgment in the Fisher case and how it is likely to impact the rules on transfer of assets abroad.
Even Closer? A Global Minimum Tax on Corporations December Update
On 8 October 2021, the OECD/G20 Inclusive Framework published a statement where 136 jurisdictions agreed to a global minimum tax on corporations (“GMCT”).
Joint and Several Liability Notices
Schedule 13 of the Finance Act 2020 (the “FA 2020”) introduced measures that allow HMRC to give joint and several liability notices (“JSLN”) to company directors, shadow directors and members of LLPs in certain circumstances.
Autumn Budget 2021: effects on tax disputes
On 27 October 2021 the Chancellor of the Exchequer unveiled the contents of the Autumn Budget 2021. The present article focuses on those specific measures that might have an effect on tax disputes.
Test Claimants in the Franked Investment Income GLO v HMRC
On 23 July 2021, the Supreme Court (“UKSC”) delivered its decision in Test Claimants in the Franked Investment Income Group Litigation v HMRC [2021] UKSC 31. This note discusses the three most significant issues – in financial terms – that were decided by the UKSC.
An Assessment to Tax is never ‘stale’, but it might be out of date: HMRC v Tooth
This article briefly discusses the key points arising out of the decision of the UK Supreme Court in HMRC v Tooth [2021] UKSC 17. The case considered (1) whether a discovery assessment could become “stale” and (2) the meaning of the phrase “deliberate inaccuracy”.
VATA 1994 s.47, Agency, Onward Supply Relief, & Double Taxation
On 12 July 2021, the First-tier Tribunal (Tax Chamber) (“FTT”) released its decision in Scanwell Logistics (UK) Limited v HMRC [2021] UKFTT 261 (TC), rejecting the taxpayer’s claim for onward supply relief (“OSR”).
Draft Finance Bill 2022—tax avoidance measures
Helen McGhee considers the draft Finance Bill 2022 clauses published on 20 July 2021 in relation to tax avoidance and recent updates to the tax avoidance regime.
Getting Closer: A Global Minimum Tax on Corporations
On 1 July 2021, US Treasury Secretary Janet Yellen announced that countries representing over 90% of global GDP had agreed to a global minimum tax on corporations (“GMCT”).
The DBKAG & K (CJEU) decision: an opportunity for investment funds?
On 17 June 2021, the European Court decided the joint cases K (C-58/20) and DBKAG (C-59/20) regarding whether the supply of certain services constituted the “management of special investment funds”, benefiting from the VAT exemption enshrined in Article 135(1)(g) of Council Directive 2006/112/EC.
Raising the bar: UK Supreme Court clarifies the requirements for HMRC to issue Follower Notices
On 2 July 2021, the Supreme Court delivered its judgment in R (on the application of Haworth) v HMRC [2021] UKSC 25, finding unanimously in favour of the taxpayer and upholding the Court of Appeal’s decision to quash the follower notice issued to him.
The End is Nigh for the Non-Dom Regime
Published in ThoughtLeaders4 Private Client Magazine, Helen McGhee expert analysis of the current state of non-dom tax regime and it's future.
On 14 June 2023, HMRC published a substantially rewritten Code of Practice 9 (“COP9”). Helen McGhee and Megan Durnford set out the key changes implemented as a result of this publication.
Pandora Papers: HMRC issues nudge letters
Helen McGhee sets out HMRC's response to the Pandora Papers leak of almost 12 million documents
Increased Investment in Personal Tax Compliance in the UK
Helen McGhee discusses the main developments in support of the increased focus on international transparency and personal tax compliance in the UK.
Tax-Related Measures in the Autumn Statement 2022
This article explores the tax measures included in the Autumn Statement 2022
Offshore Structures and Onward Gifts
This article explores the "onward gift" tax anti-avoidance rules introduced by the Finance Act 2018.
Increased Investment in Personal Tax Compliance in the UK
This article discusses the main developments in support of the increased focus on international transparency and tax compliance in the UK.
Case note: Lynton Exports (Alsager) Ltd v Revenue and Customs Commissioners [2022] UKFTT 00224 (TC)
JHA’s latest insight into the First-tier Tribunal’s decision in Lynton Exports (Alsager) Ltd v Revenue and Customs Commissioners [2022] UKFTT 00224 (TC).
What is domicile and why does it matter for tax?
A quick review of the fundamental principle of domicile, why it matters for tax, and what the current political landscape has in store.
Tax note: Financial Institution Notices (FIN)
Understanding paragraph 4A of Schedule 36 to the Finance Act 2008
FTT Decision on Excise Duty in Cantina Levorato SRL v HMRC [2021] UKFTT 461 (TC)
A Short Case Report on the FTT decision in Cantina Levorato SRL v HMRC [2021] UKFTT 461 (TC)
Fast Track for Register of Overseas Entities Owning UK Property
The invasion of Ukraine has prompted the UK government to speedily publish the draft legislation for the Economic Crime (Transparency and Enforcement) Bill 2022.
Global Minimum Tax on Corporations: OECD GloBE Model Rules and their implementation in the UK
On 8 October 2021, the OECD/G20 published a statement confirming that 136 jurisdictions had agreed to a two-pillar solution to address the tax challenges that arise from the digitalisation of the economy and setting out an implementation plan.
‘MTIC’ Fraud – Kittel Test PTGI International Carrier Service Limited v. HMRC [2022] UKFTT 20 (TC)
A summary of the FTT decision in PTGI International Carrier Service Limited v. HMRC [2022] UKFTT 20 (TC)
HMRC consultation on the OECD mandatory disclosure rules
HMRC has published a consultation on draft regulations to implement the Organisation for Economic Cooperation and Development (OECD) rules on mandatory disclosure of certain avoidance arrangements. Helen McGhee explains the background to the new rules and their implications.
Post-Prudential: Decision released by the FTT
On 8 December 2021, judgment in the Post Prudential Group Litigation was handed down by the First-tier Tribunal (Tax Chamber) (“FTT”).
S&S Consulting Services (UK) Ltd v HMRC: Can a company be re-registered for VAT pending appeal?
On 26 November 2021, the High Court of Justice issued its judgment in S&S Consulting Services (UK) Ltd, R (On the Application Of) v HM Revenue and Customs [2021] EWHC 3174
VAT De-registration: the CJEU decision in the Promexor case
On 18 November 2021, the Court of Justice of the European Union (the “CJEU”) delivered its judgment in Case C-385/20 (Promexor Trade SRL v Directia Generala a Finantelor Publice Cluj – Administratia Judeteana a Finantelor Publice Bihor).
Helen McGhee discusses the use of corporate vehicles in family wealth and succession planning in the UK
Helen McGhee considers the Court of Appeal’s judgment in the Fisher case and how it is likely to impact the rules on transfer of assets abroad.
Even Closer? A Global Minimum Tax on Corporations December Update
On 8 October 2021, the OECD/G20 Inclusive Framework published a statement where 136 jurisdictions agreed to a global minimum tax on corporations (“GMCT”).
Joint and Several Liability Notices
Schedule 13 of the Finance Act 2020 (the “FA 2020”) introduced measures that allow HMRC to give joint and several liability notices (“JSLN”) to company directors, shadow directors and members of LLPs in certain circumstances.
Autumn Budget 2021: effects on tax disputes
On 27 October 2021 the Chancellor of the Exchequer unveiled the contents of the Autumn Budget 2021. The present article focuses on those specific measures that might have an effect on tax disputes.
Test Claimants in the Franked Investment Income GLO v HMRC
On 23 July 2021, the Supreme Court (“UKSC”) delivered its decision in Test Claimants in the Franked Investment Income Group Litigation v HMRC [2021] UKSC 31. This note discusses the three most significant issues – in financial terms – that were decided by the UKSC.
An Assessment to Tax is never ‘stale’, but it might be out of date: HMRC v Tooth
This article briefly discusses the key points arising out of the decision of the UK Supreme Court in HMRC v Tooth [2021] UKSC 17. The case considered (1) whether a discovery assessment could become “stale” and (2) the meaning of the phrase “deliberate inaccuracy”.
VATA 1994 s.47, Agency, Onward Supply Relief, & Double Taxation
On 12 July 2021, the First-tier Tribunal (Tax Chamber) (“FTT”) released its decision in Scanwell Logistics (UK) Limited v HMRC [2021] UKFTT 261 (TC), rejecting the taxpayer’s claim for onward supply relief (“OSR”).
Draft Finance Bill 2022—tax avoidance measures
Helen McGhee considers the draft Finance Bill 2022 clauses published on 20 July 2021 in relation to tax avoidance and recent updates to the tax avoidance regime.
Getting Closer: A Global Minimum Tax on Corporations
On 1 July 2021, US Treasury Secretary Janet Yellen announced that countries representing over 90% of global GDP had agreed to a global minimum tax on corporations (“GMCT”).
The DBKAG & K (CJEU) decision: an opportunity for investment funds?
On 17 June 2021, the European Court decided the joint cases K (C-58/20) and DBKAG (C-59/20) regarding whether the supply of certain services constituted the “management of special investment funds”, benefiting from the VAT exemption enshrined in Article 135(1)(g) of Council Directive 2006/112/EC.
Raising the bar: UK Supreme Court clarifies the requirements for HMRC to issue Follower Notices
On 2 July 2021, the Supreme Court delivered its judgment in R (on the application of Haworth) v HMRC [2021] UKSC 25, finding unanimously in favour of the taxpayer and upholding the Court of Appeal’s decision to quash the follower notice issued to him.