Jonathan Peacock KC

While he is available to advise on, and act in litigation relating to, any tax matter, his recent focus has been on the following areas:

International tax issues – Jonathan advises on all international and cross-border tax issues (permanent establishments, transfer pricing/DPT, profit attribution, entity classification, double tax relief, residence and domicile questions) and has appeared in significant double tax relief cases in the UK courts. He has been instructed in tax related arbitrations and as an advocate, adviser and expert witness in overseas litigation in jurisdictions as far afield as Jersey, Tanzania, Mauritius, Canada and the USA.  He has also advised on matters of non-UK tax law, typically in common law countries where the provisions are based on UK law and UK law has some persuasive effect (e.g. Ireland, Jersey, Guernsey, Hong Kong and Singapore). 

VAT – Jonathan has extensive experience of VAT matters, particularly relating to the scope of exemptions in the financial and insurance services sectors; the application of the ‘use and enjoyment’ rules in the telecommunications sector; the scope of retail loyalty schemes and the voucher rules; and the recovery of overpaid VAT.

Energy and the extractive industries – Jonathan’s experience relates predominantly to oil and gas in the UK North Sea but also covers hydro-electric, wind, solar and nuclear power.  Principal areas of interest are the North Sea fiscal regime, both inside and outside the ‘ring fence’, the tax consequences of decommissioning and capital allowances on other plant and machinery.  Jonathan also has experience of advising on non-UK energy and mining assets in Africa, Asia, Gulf of Mexico and South America.

Sports tax matters – Jonathan has broad expertise, both as an adviser and as an advocate, in relation to sport governing bodies, professional and amateur clubs, sponsorship, stadium developments, club financing, player remuneration, agent issues and image rights.

Betting and gaming, especially the indirect tax treatment of gambling, both online and offline.

Real estate development in the UK, both as regards corporation tax and SDLT.

Pensions and employee remuneration matters, particularly relating to ‘disguised remuneration’ and offshore pension schemes. Jonathan has a current focus on the employment, self-employment divide, particularly in the media industry.

Financial institutions and financial services – Jonathan has over 20 years’ experience of advising (and litigating) in relation to capital market, corporate finance, venture capital, structured finance and finance leasing transactions. He also has broad experience of asset management (particularly hedge funds) and open-ended and closed funds.

The tax aspects of criminal and regulatory investigations.

Jonathan frequently appears in courts and tribunals in the UK and Europe (including the UK Supreme Court, the European Court of Justice and the European Court of Human Rights) on tax matters and has acted both for and against the UK Government in tax avoidance cases. 

Jonathan has led seminars on the Oxford University BCL and Master in Law and Finance courses, is a member of the External Faculty for the Oxford MSc in Taxation course and is the author of numerous articles and several books on aspects of revenue law.