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Zizhen Yang

“bright, meticulous in her approach and excellent when it comes to analysis of the case."

Chambers & Partners

"Zizhen is really good - really sharp and very impressive."

Chambers & Partners

"She impresses enormously."

Legal 500
  • Call: 2009

Overview

Winner of Tax Junior of the Year in The Legal 500 UK Awards 2024, and previously 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 “simply excellent”, “really sharp and very impressive”, “totally engaged” and having “a deep knowledge and understanding of tax”, she is “brilliant, bright, hard-working and focused” and “meticulously well-prepared” with “clarity of thought and insight”.

Zizhen is noted for her advocacy in court, for which she is described as “impressive”, “eloquent and intelligent” and “very organised and unflappable”.  She is “a precise, clear and resilient advocate” whose oral submissions “are clear and to the point”, and delivered “in a very clear and measured way”.  She “produces outstanding drafting” that is “very articulate [and] precise”, and “her knowledge and judgment are excellent”.  When advising, Zizhen is described as having “a phenomenal understanding and knowledge of not just the VAT legislation, but all the rules and guidance notes too”.  She is “an exemplary lawyer with a keen intellect” whose “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 “so calm and collected in the face of complicated tax matters”, “very collaborative in approach and incredibly clever – a real pleasure to work with”.  She “provides a premier standard of service”, and 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 and landfill tax, 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 sole advocate in the Supreme Court, the Court of Appeal, the High Court, the Upper Tribunal, and the First-tier Tribunal, as well as having appeared in the Court of Justice of the European Union.

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.

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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:

VAT

Landfill tax

Recent cases include:

  • Devon Waste Management Ltd & ors v HMRC (Court of Appeal; Upper Tribunal; First-tier Tribunal): 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 (Court of Appeal; Upper Tribunal; First-tier Tribunal): 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”.

SDLT

Recent cases include:

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:

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.

 

Judicial review

“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:

  • 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.

Penalties and costs

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

Directory Recommendations

Chambers UK Bar

Indirect Tax: London (Bar)
Ranking: Band 1

  • “Zizhen Yang is eloquent and intelligent.” “Zizhen Yang is very strong technically.” “There were difficult, technical and important consequences in the case and Zizhen was clear and not afraid to impart bad news. She was calm and explained complex concepts well.” (2026)
  • “Zizhen is excellent. She’s very thorough, she’s very thoughtful and she drafts well.” “Zizhen is technically very strong and a pleasure to work with.” “She is very detailed in her approach and a specialist in areas that are quite unusual.” (2025)
  • “Zizhen is very detail-focused and is excellent at helping those that instruct her through tough situations.” “Thorough and clear at all times, she takes a proactive and commercial approach to resolving issues with HMRC.” “Zizhen was very reassuring in front of the client during the course of the hearing. On her feet she clearly articulated difficult concepts to the judge.” “Highly intelligent and deeply experienced, she provides a premier standard of service.” (2024)
  • “Zizhen is a very clear-thinking and extremely diligent barrister.” “She provides excellent client service and clear advice.” (2023)
  • “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)

Tax: London 
Ranking: Band 3

  • “Zizhen is really good – really sharp and very impressive. She delivers submissions in a very clear and measured way.” (2026)
  • “She’s excellent and the quality of her preparation shines through at every stage of the case.” (2025)
  • “An extremely polished barrister.” “Incredibly clever, she formulates complex solutions to knotty problems.” (2024)
  • “Zizhen Yang is so calm and collected in the face of complicated tax matters. She doesn’t know just her stuff, she is all over it.” (2023)
  • “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)
  • “An excellent junior who is very articulate and good at drafting.” “She has always impressed me with her work ethic and ability to cut through to the heart of an issue.” (2019)

The Legal 500 UK Bar

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

  • “Zizhen is really good – really sharp and very impressive. She delivers submissions in a very clear and measured way.” (2026)
  • “She’s excellent and the quality of her preparation shines through at every stage of the case.” (2025)
  • “An extremely polished barrister.” “Incredibly clever, she formulates complex solutions to knotty problems.” (2024)
  • “Zizhen Yang is so calm and collected in the face of complicated tax matters. She doesn’t know just her stuff, she is all over it.” (2023)
  • “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)
  • “An excellent junior who is very articulate and good at drafting.” “She has always impressed me with her work ethic and ability to cut through to the heart of an issue.” (2019)

Tax: Corporate
Ranking: Leading Junior, Tier 1

  • “Zizhen is simply excellent. She is meticulously well-prepared. Her written advocacy is persuasive. Her oral submissions are clear and to the point.” (2025)
  • “A keen eye for detail, very collaborative in approach and incredibly clever – a real pleasure to work with.” (2024)
  • “Technically strong and very hard working.” (2021)

Memberships

  • Revenue Bar Association
  • VAT Practitioners Group

Languages

  • Chinese (Mandarin) (bilingual)

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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