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Leslie Allen, Partner, Dispute Resolution

Leslie Allen

Consultant, Barrister

Personal Profile

Leslie is a Consultant, Barrister in the Dispute Resolution department focusing on tax litigation and investigations tax. He has over 30 years experience in the conduct of complex disputes and has been responsible for the conduct of high profile litigation at all levels from the Tax Tribunal through to the Supreme Court and the Court of Justice of the European Union. He has previously worked with HM Customs and Excise Solicitors Office, KPMG and Ernst & Young.

In recent years he has become heavily involved in direct tax disputes ranging from residence to corporation tax disputes. Leslie's experience includes assisting clients with the increased burden they face in dealing with aggressive tactics employed by the authorities such as dawn raids and investigations.

Key Experience

  • Acting as Lead Solicitors on the largest Group Litigation Order in the history of tax litigation. We represent almost 300 claimants in a case involving examination of European and domestic law obligations on Royal Mail as an emanation of the state.
  • Acting for Mercedes-Benz Financial Service (UK) Limited in respect of its appeal to the Court of Justice of the European Union as to whether supplies of certain financial products are supplies of goods or supplies of services for the purposes of Value Added Tax.
  • Conducted a variety of types of litigation before the Courts. These range from civil penalties, mark up disputes, civil fraud, technical disputes, lengthy factual issues and all range of matters that come before Tax Tribunal. In particular he has been involved in:
  • The London Zoo case where he represented all the charitable zoos in the UK and succeeded in getting exemption for them on the basis they were all managed and administered on a voluntary basis.
  • Involved in various cases for British Telecommunications Plc in particular recovering monies for innocent error and dealing with complex capping provisions.
  • Carlton Clubs Limited. Dealing with an issue relating to competing claims and successfully concluding that the right party to the claim was Carlton Clubs and not the original parent company.
  • Thorn Plc where he dealt with the issue of "free" phones and the right to deduct input tax.
  • Mercedes-Benz Financial UK Limited and the issue as to whether supplies of certain products made them supplies of goods or supplies of services.
  • Micro Fusion and looking at the first of the film finance disputes that has hit the Courts.
  • Ford Motor Company Limited dealing with an issue in relation to the new penalty regime and the way that HMRC dealt with issues relating to large traders.
  • Glasgow City Council where Leslie argued and successfully recovered in excess of £50,000,000 for the Council on the basis that HMRC had for many years wrongly treated the supplies in maintaining buildings as being a business rather than non business supply.
  • Harrier LLC & Others. The first lead case to be heard in the Tax Tribunal. He successfully argued on behalf of Harrier and all the other joined to the lead case that the supplies they were making were books and therefore zero rated. This led to HMRC changing their whole approach to these supplies.
  • RCI Europe. Case went to the European Court of Justice and was dealing with complex issues relating to place of supply, in relation to services carried out throughout Europe.
  • He has also dealt in the Tax Tribunal with issues relating to valuation of property whereby it was essentially an argument of using expert witnesses to determine what was the correct value to be attached to the property.
  • He has had considerable experience in the area of excise duty and did for a number of clients in or around the issue of Greenalls successfully reaching settlement in many of them.
  • He has been involved in issues relating to landfill taxes and where the product was in fact necessary for the sealing of the landfill site and was not in fact being disposed of.
  • He has been involved in many of the tax planning cases from BUPA hospitals onwards and has experience in dealing with the arguments and issues that arise in these areas.
  • Currently Leslie is having to deal with issues relating to double tax treaties where you have situations where both authorities think they are entitled to the monies and ensuring that the client is not prejudiced by being effectively taxed twice.
  • He has also been involved in some leading investigations where he has successfully been able to get involved and ensure that a settlement was negotiated without the need for recourse to the Courts.
  • He has experience with Employment Benefit Trusts including examining if they were correctly implanted and where not negotiating settlement with HMRC.
  • He has led the litigation following on from the TNT case on VAT and postage and making substantial claims on behalf of traders.

Career History

Partner, Mishcon de Reya LLP
Senior Consultant, DLA Piper UK LLP
Partner, Dorsey & Whitney
Director, Ernst & Young

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