Contact details

Hugo Jenney

T: +44 20 7809 2186 M: +44 7917 058 472 Email Hugo | Vcard Office: London

Awards

Hugo Jenney Partner

Contact details

Hugo Jenney

Hugo Jenney
Partner

T: +44 20 7809 2186 M: +44 7917 058 472 Email Hugo | Vcard Office: London

Heading the firm's tax team for the last 15 years, Hugo is a corporate tax lawyer with significant experience of tax-based structured finance and handling high value tax settlements and litigation. He is a leading tax advisor to shipping, aircraft and rail companies but also advises real estate and investment funds and high net worth families.
  • Profile
  • Services
  • Sectors

Hugo is one of the leading tax advisors to the transport sector having advised the firm's transport and finance client base for many years. During that time he established himself as one of the few authorities on tonnage tax and has advised on more tax-based leases than virtually any other advisor. He also advises on tax structuring of international shipping groups and is an expert on VAT, including on yachts and jets.

Hugo has advised extensively on structuring inward investment into UK real estate. He is a member of the Law Society Stamp Duty Committee and the VAT Practitioners Group.

Through advising owners of various transport-related, real estate and investment funds businesses, Hugo has developed an expertise in advising on asset-holding structures for tax, succession planning and asset protection purposes. This has also involved advising on foreign domiciliary structures and private equity/hedge fund remuneration structures.

Hugo particularly enjoys handling tax enquiries and disputes with HMRC. The most significant enquiries involve very large amounts of tax and require the approval of the HMRC Board and Tax Assurance Commissioner.

He has been recommended in The Legal 500 and Chambers UK for over 15 years​.


 "A strong reputation for his work in tax leasing"

Chambers UK 2014
  • Tax
  • Marine and international trade
  • Real estate
  • Finance
  • Dispute resolution

Shipping group structures

Advised on the optimum ownership and financing structure for their UK shipping operations and how to structure UK tonnage tax groups.

Langham Estate, real estate refinancing and group restructuring

Advised the real estate owner on the £540m refinancing of this portfolio.

Hedge fund manager, profit extraction

Advising on the creation of a "tax-free" offshore structure for a UK resident national and the subsequent exit-planning.

High net worth client, succession and tax planning

Advising an ultra-high net worth client over a 10 year period on succession structures, residence and real estate tax planning.

Client family, establishing an English and Hong Kong charity and $100m+ charitable donation

Advising on the establishment of the charities, tax relief aspects and the donation agreement.

Various clients, tax enquiries and tax disclosures

Advising in relation to HMRC enquiries, whether on technical points or involving allegations of fraud

Advising clients on the disclosure to the UK tax authorities of undisclosed assets and the relative merits of the Liechtenstein disclosure facility and other disclosure opportunities.

More: Tax

Various companies, tax leasing enquiries

Advised in relation to tax enquiries into various complex leasing structures involving very significant amounts of tax.

Various shipping companies, shipping group structures

Advised on the optimum ownership and financing structure for their UK shipping operations and how to structure UK tonnage tax groups.

Various shipping companies, lease exits/restructures

Advising on the restructuring of and exits from different types of tax-based leasing structure.

Various private individuals, VAT and yachts

Advised on the VAT implications of importing their yachts into the EU and the conditions for temporary importation relief and leasing structures.

More: Marine and international trade

Hugo has advised clients such as Accor Hotels, Greenwich University, Lasalle Investments and the Langham Estate.

The Langham Estate, £540m refinancing and restructuring

Advising this long-standing client on the refinancing and more generally on group structuring matters.

Real estate client, REITs

Advised on various REIT-related matters including a tender offer on the London Stock Exchange.

Helios PLC, group structuring

Advising this property group on various restructurings.

Real estate holding structures

Advising on structures for the holding of residential property subject to the new annual tax on enveloped dwellings; also advising on structures for commercial property investment and development.

More: Real estate

Chambers UK described Hugo as "having a strong reputation for his work in tax leasing".

UK Bank, lease financing

Advising on the purchase of equipment and rights under an operating lease.

Macquarie Bank, receivables financing

Advising on the purchase of lease receivables in various European countries.

Canadian pension fund, lease receivables securitisation

Advising on the securitisation of lease receivables.

Lombard, financings

Giving tax advice and sign-off on various loan, lease and hire purchase financings.

Insurance company, leaseco purchase

Advising on the interim financing and subsequent acquisition of a bank subsidiary with a portfolio of tax-based rail depot leases.

Various banks and aircraft owners, VAT and aircraft

Advising on the implications of importing aircraft into the EU, availability of temporary importation relief and leasing structures.

More: Finance

Various clients, tax Leasing enquiries

Advised in relation to tax enquiries into various complex leasing structures involving very significant amounts of tax.

Numerous clients, tax enquiries and tax disclosures

Advising in relation to HMRC enquiries, involving technical points and allegations of fraud

Advising clients on the disclosure to the UK tax authorities of undisclosed assets and the relative merits of the Liechtenstein disclosure facility and other disclosure opportunities.

Metal trader and customs warehouse owner, VAT enquiries

Advising on HMRC information powers and the implications of unauthorised withdrawals from a warehouse.

More: Dispute resolution
  • Shipping
  • Banks and banking
  • Funds and financial services
  • Real estate investors and developers
  • Private wealth

​Various shipping companies, tax leasing enquiries

Advised in relation to tax enquiries into various complex leasing structures involving very significant amounts of tax.

Various shipping companies, shipping group structures

Advised on the optimum ownership and financing structure for their UK shipping operations and how to structure UK tonnage tax groups.

Various shipping companies, lease exits/restructures

Advising on the restructuring of and exits from different types of tax-based leasing structure.

Various private individuals, VAT and yachts

Advised on the VAT implications of importing their yachts into the EU and the conditions for temporary importation relief and leasing structures.

More: Shipping

UK bank, lease financing

Advising on the purchase of equipment and rights under an operating lease.

Macquarie Bank, receivables financing

Advising on the purchase of lease receivables in various European countries.

Canadian pension fund, lease receivables securitisation

Advising on the securitisation of lease receivables.

Lombard, financings

Giving tax advice and sign-off on various loan, lease and hire purchase financings.

Insurance company, Leaseco purchase

Advising on the interim financing and subsequent acquisition of a bank subsidiary with a portfolio of tax-based rail depot leases.

Various banks and aircraft owners, VAT and aircraft

Advising on the implications of importing aircraft into the EU, availability of temporary importation relief and leasing structures.

More: Banks and banking

Investor, social housing fund

Advised the main investor in a fund which focuses on providing social housing.

SQN Asset Finance Income Fund, initial capital raise

Advising on the launch of a new Guernsey-listed fund investing in US and UK equipment leasing and asset finance.

Shipowner client, launch of shipping fund

Advising on the structuring of a shipping fund.

Hedge fund manager, profit extraction

Advising on the creation of a "tax-free" offshore structure for a UK resident national and the subsequent exit-planning.

Non-domiciled UK resident manager, private equity

Advising on the structuring of a manager interest in a private equity fund using an offshore trust to maximise tax efficiency.

More: Funds and financial services

The Langham Estate, £540 million refinancing and group restructuring

Advising this long-standing client on the refinancing and more generally on group structuring matters.

Real estate client, REITs

Advised on various REIT-related matters including a tender offer on the London Stock Exchange.

Helios PLC, group structuring

Advising this property group on various restructurings.

Various clients, real estate holding structures

Advising on structures for the holding of residential property subject to the new annual tax on enveloped dwellings

Advising on structures for commercial property investment and development.

More: Real Estate investors and developers

High net worth client, succession and tax planning

Advising an ultra-high net worth client over a 10 year period on succession structures, residence and real estate tax planning.

Client family, establishing an English and Hong Kong charity and $100m+ charitable donation

Advising on the establishment of the charities, tax relief aspects and the donation agreement.

Various Belgian and French nationals, international succession planning

Advising on the implications of becoming UK tax resident on their "continental style" tax structures, including consideration of usufruct and quasi-usufruct structures.

Various Russian and other individuals, tax on migration to UK

Advising on pre-arrival and post-arrival tax planning, immigration aspects and optimisation of tax treaty benefits.

Nigerian family, succession planning

Advising a high net worth Nigerian family on an offshore structure providing tax and asset protection.

Numerous clients, tax enquiries and tax disclosures

Advising in relation to HMRC enquiries, involving technical points and allegations of fraud

Advising clients on the disclosure to the UK tax authorities of undisclosed assets and the relative merits of the Liechtenstein disclosure facility and other disclosure opportunities.

More: Private wealth

Awards

Latest news & insights

08 Jun 2017

From Insights

VAT on leasing and hire purchase: goods or services?

On 31 May 2017 Advocate General Szupnar delivered his opinion in the Mercedes-Benz Financial Services UK Ltd case. The case addresses how to distinguish between those ..

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29 Apr 2016

From News

Stephenson Harwood advises on biggest charitable gift of 2015

International law firm Stephenson Harwood LLP has advised property developer Samuel Tak Lee on the largest charitable donation given by a UK-based individual in 2015.

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13 Jul 2014

From News

Stephenson Harwood advises on the launch of SQN Asset Finance Income Fund Limited

Stephenson Harwood LLP advised on the launch of a new equipment leasing fund, SQN Asset Finance Income Fund Limited (SQN).

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06 Apr 2014

From News

Stephenson Harwood boosts private wealth team with new hire

Stephenson Harwood LLP appoints James Quarmby as a partner, to spearhead the expansion of the firm's private wealth team.

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10 Nov 2013

From Insights

EU resists changes to tonnage tax

Following a recent review, the European Commission has decided not to revise its Maritime State Aid Guidelines in the near future. Find out more.

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06 Sep 2013

From Insights

Media coverage: International Financing Review

Hugo Jenney comments on Corporate tax paid by UK banks almost doubling during the past fiscal year, despite a decline in profitability for many firms during the period..

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