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Zizhen Yang

“Zizhen is very helpful throughout and is very keen to accommodate those that instruct her."

Chambers & Partners 2022
  • Call: 2009

Overview

Nominated as Tax Junior of the Year in both the Chambers and Partners UK Bar Awards 2020 and The Legal 500 UK Awards 2020 and 2022, Zizhen has been consistently ranked in both directories. Described by clients and colleagues in the legal directories as “totally engaged” and having “a deep knowledge and understanding of tax”, she is “brilliant, bright, hard-working and focused”, “meticulous in her approach”, “excellent when it comes to analysis of the case”, and “an excellent junior”.

Zizhen is noted for her advocacy in court, for which she is described as “impressive”, a “very thoughtful advocate” and “very organised and unflappable”. She “produces outstanding drafting” that is “very articulate [and] precise”, and “her knowledge and judgment are excellent”.  When advising, Zizhen is described as “creative and very, very good with technical arguments”, “her analytical skills are top-rate”, “she comes up with things that other people haven’t really identified”, and she has the “ability to cut through to the heart of an issue”.

Zizhen is also “user-friendly”, “well liked and highly regarded”, “incredibly industrious”, “phenomenally hard-working” and “enormously responsive”.  Clients describe her as “very helpful throughout and very keen to accommodate those that instruct her”. She is generally recommended as “enormously impressive”.

Possessing a depth of experience across the spectrum of tax issues, in addition to experience in commercial matters, Zizhen is particularly well noted for her extensive experience in indirect tax. Her practice has spanned a number of high-profile cases, most recently in VAT, landfill tax and SDLT, in addition to other areas.

As well as a wide-ranging advisory practice, Zizhen has a wealth of litigation experience in both trial and appellate advocacy, having appeared as the advocate in the Court of Appeal, the High Court, the Upper Tribunal, and the First-tier Tribunal, as well as having appeared in the European Court of Justice.

Zizhen is happy to accept instructions under the Joint Advisory Scheme and Special Advocacy Scheme. She is also qualified to accept Public Access instructions.

A copy of Zizhen's privacy notice can be found here.

Corporate tax

“Totally engaged and gives very good advice on complex tax planning. Zizhen is very bright, meticulous in her approach and excellent when it comes to analysis of the case.”

Recent work includes:

DMWSHNZ Ltd v HMRC (First-tier Tribunal; Upper Tribunal; Court of Appeal): CGT group relief; debt redemption.

Abbey National Treasury Services Plc v HMRC (First-tier Tribunal): loan relationship rules; derivative contracts; legal and accounting concepts of loss; derecognition; transfer pricing.

Cater Allen International Ltd & anr v HMRC (First-tier Tribunal): loan relationships; repo over interest coupons; legal and accounting concepts; fair representation of profit.

Euroceanica (UK) Ltd v HMRC (First-tier Tribunal): tonnage tax; relevant shipping income; loan finance.

Purolite International Ltd v HMRC (First-tier Tribunal): deductible expense; “wholly and exclusively” test.

The First De Sales Limited Partnership (First-tier Tribunal; Upper Tribunal): strike out application; whether reasonable prospect of finding payments made “in respect of” the giving of restrictive undertaking by employee; whether reasonable prospect of deduction being allowed against profits of trade

Income tax/CGT/capital allowances

“Her preparation is impressive, her analytical skills are top-rate and she’s a very thoughtful advocate. She is phenomenally hard-working, possesses very good drafting skills and is enormously responsive.”

Recent work includes:

The Partners of the Vaccine Research Limited Partnership and Lionel Patrick Vaughan v HMRC (First-tier Tribunal; Upper Tribunal): capital allowances; expenditure on research and development; sham; location of trade; commercial basis with a view to profit; expenditure wholly and exclusively for purpose of trade; relief for loan interest.

The Brain Disorders Research LP & anr v HMRC (First-tier Tribunal): capital allowances; expenditure on research and development; commercial basis with a view to profit; expenditure wholly and exclusively for purpose of trade; relief for pre-payments of interest.

Price & ors v HMRC (First-tier Tribunal; Upper Tribunal): bargain at arm’s length; employment-related convertible securities; employment-related securities options; retrospective legislation; CGT losses; qualifying trading company.

The First De Sales Limited Partnership & ors v HMRC (First-tier Tribunal; Upper Tribunal): strike out application; whether reasonable prospect of finding payments made “in respect of” the giving of restrictive undertaking by employee; whether reasonable prospect of deduction being allowed against profits of trade; sideways loss relief.

Amit Patel v HMRC (First-tier Tribunal): application to stay substantive tax appeal pending outcome of related civil litigation; whether stay would avoid unnecessary costs to parties and the Tribunal; whether fair, just and proportionate to grant stay.

Procedural propriety of FTT’s approval of taxpayer notices on ex parte application by HMRC under para 3 Sch 36 FA 2008; rationality and reasonableness of HMRC’s decision to request certain documents and information for purpose of checking taxpayer’s tax position.

Simon Fry v HMRC (First-tier Tribunal): CGT; penalty for inaccuracy in return; carelessness; “no reasonable prospect” of using loss claimed; potential lost revenue.

Simon Fry v HMRC (First-tier Tribunal): unreasonable conduct; failure to notify respondent of postponement application; party failing to attend hearing on purported medical grounds.

 

Property tax

“Incredibly hard-working and has all the technical skills required. She is incredibly industrious and does a lot of the heavy lifting in a case.”

Recent work includes:

Patersons of Greenoakhill v HMRC (First-tier Tribunal; Upper Tribunal; Court of Appeal): renewable energy generation; waste; “intention to discard”.

Devon Waste Management Ltd & ors v HMRC (First-tier Tribunal; Upper Tribunal; Court of Appeal): material used to protect cell liner and cap; whether “disposal made with the intention of discarding” the material; whether “disposal made by way of landfill”; whether use of material a “prescribed activity”.

Biffa Waste Services Ltd v HMRC (First-tier Tribunal; Upper Tribunal; Court of Appeal): shredded material used to protect cap of landfill cell; whether “disposal made with the intention of discarding” the material; whether “disposal made by way of landfill”; whether use of material a “prescribed activity”.

Pollen Estate Trustee Co Ltd and King’s College London v HMRC (First-tier Tribunal; Upper Tribunal; Court of Appeal): charities exemption.

 

 

VAT

“Her knowledge and judgement are excellent, and her drafting skills are strong. Zizhen is very helpful throughout and is very keen to accommodate those that instruct her.”

Recent work includes:

Bookit Ltd v HMRC (First-tier Tribunal; CJEU): financial services exemption; debt collection; abuse.

British Film Institute v HMRC (First-tier Tribunal; Upper Tribunal; Court of Appeal; CJEU): cultural services exemption; direct effect.

Trinity Mirror Plc v HMRC (First-tier Tribunal; Upper Tribunal): default surcharge for late payment; proportionality.

Prudential Assurance Company Ltd v HMRC (First-tier Tribunal): application of time-of-supply rules to intra-group supply of services invoiced after supplier leaves the VAT group; effect of section 43(1) VATA 1994.

G4S Corporate Services Ltd & anr v HMRC (First-tier Tribunal): whether interest due to HMRC where late paid VAT held by Home Office and as such no loss to “the Crown”.

D Jacobson & Sons Ltd v HMRC (First-tier Tribunal): bad debt relief; consideration for a supply.

PayPoint Collections Ltd & anr v HMRC (First-tier Tribunal): financial services exemption; provision of payment system.

Quitie Ltd v HMRC (First-tier Tribunal): zero-rating; supply of construction services commencing prior, and completing subsequent, to discharge of planning condition restricting separate sale of dwelling.

Directory quotes

The Chambers Guide

Tax: London (Bar)
Ranking: Band 3

“Totally engaged and gives very good advice on complex tax planning.” “She is very bright, meticulous in her approach and excellent when it comes to analysis of the case.” (2022)

“Incredibly hard-working and has all the technical skills required. She is incredibly industrious and does a lot of the heavy lifting in a case.” (2021)

“Creative and very, very good with technical arguments, she comes up with things that other people haven’t really identified.” (2020)

Indirect Tax: London (Bar)
Ranking: Band 2

“Her knowledge and judgement are excellent, and her drafting skills are strong.” “She is very helpful throughout and is very keen to accommodate those that instruct her.” (2022)

“Brilliant, bright, hard-working and focused.” (2021)

“Her preparation is impressive, her analytical skills are top-rate and she’s a very thoughtful advocate.” “She is phenomenally hard-working, possesses very good drafting skills and is enormously responsive.” (2020)

The Legal 500

Tax: VAT & Corporate
Ranking: Leading Junior, Tier 1

“Technically strong and very hard working.” (2021)

“She impresses enormously with her incredible capacity to produce high-quality documents and arguments in a very short time.” (2020)

“She has a deep knowledge and understanding of tax.” (2019)

Languages

  • Chinese (Mandarin) (bilingual)

Memberships

  • Revenue Bar Association
  • VAT Practitioners Group

Career & education

2011
6-month secondment at Slaughter and May (tax department).

2010 – date
Tenant (Pump Court Tax Chambers).

2009-2010
Pupillage: Pump Court Tax Chambers (July – October 2010); Serle Court (October 2009 – July 2010).

2009
Called to the Bar (Lincoln’s Inn).

2008-2009
Bar Vocational Course, City Law School — Outstanding
Lord Mansfield Scholarship (Lincoln’s Inn); Buchanan Prize (Lincoln’s Inn); Barstow Scholarship (City Law School); Busfield Prize (ICLR).

2007-2008
CPE/Graduate Diploma in Law, City University London — Distinction
Lord Bowen Scholarship (Lincoln’s Inn); Hardwicke Entrance Award (Lincoln’s Inn); Serle Court Essay Prize for Equity and Trusts.

2003-2007
PhD and Post-doctoral work in molecular immunology, Trinity College, Cambridge and MRC Laboratory of Molecular Biology
MRC Pre-doctoral Fellowship; Trinity College Research Scholarship.
MA (Cantab)

2000-2003
BA (Hons) Natural Sciences, Trinity College, Cambridge — First Class
Trinity College Examination Prize (2001–2003); Trinity College Senior Scholarship (2001–2003); Percy Pemberton Prize (Trinity College); De Lancey Scholarship (Trinity College).

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