Based on the trailer, I'd say so. An apt choice, isn't it? The Chocolate Factory ≈ Neverland.
UPDATE: Chris emails:
Why didn't you mention in your Johnny Depp post that this is the second consecutive role in which he seems to indirectly be playing Michael Jackson (the first being Finding Neverland)? I agree that he looks eerily like Jackson in the trailer.
ANOTHER UPDATE: Here's my conclusion, after seeing the movie, about whether Depp based his character on Michael Jackson.