Shanzé Shah

Shanzé has a busy advisory and disputes practice covering the full range of private client and business taxation, with particular emphasis on inheritance tax, capital gains tax, the taxation of non-UK residents and internationally mobile clients, and the taxation of charities. She is co-author of Taxation of Charities and Nonprofit Organisations (with James Kessler KC and Etienne Wong) and writes regularly for LexisNexis and Tolley’s.

Much of her advisory work involves cross-border structures: offshore trusts and SPVs, excluded property planning following the Finance Act 2025 reforms, pre-arrival and pre-departure planning, and the interaction of UK taxes with foreign situs assets. Alongside this she has a growing contentious practice, acting in appeals and enquiries before the First-tier Tribunal and advising on appeals to the Upper Tribunal.

Recent matters include:

• Excluded property and situs planning for non-UK resident individuals following the FA 2025 reforms to the taxation of non-domiciliaries, including the foreign income and gains (FIG) regime
• IHT and CGT advice on the disposal and lifetime transfer of shares in offshore SPVs holding UK residential property
• Declarations of trust and deeds of termination in respect of foreign situs assets held on bare trust
• Business property relief on a mixed lettings estate
• Gift Aid and qualifying donations under s.414 ITA 2007, including charity insolvency.
• Part 7A ITEPA 2003 (disguised remuneration).
• Transfer of assets abroad (ToAA)
• SDLT on leasehold restructuring, including Schedule 4ZA, s.53 FA 2003 and group relief
• The VAT and direct tax treatment of Islamic finance structures (murabaha and wakala).
• Taxation of charities, including the Finance Act 2026 reforms to charitable reliefs

Disputes, compliance, and procedure:

• Personal liability notices under paragraph 19, Schedule 24 FA 2007.
• VAT appeals before the First-tier Tribunal, including Kittel denials, joinder and stay applications, and case management directions.
• Merits of appeals to the Upper Tribunal, including input tax and Regulation 29(2) issues.
• HMRC statutory reviews, ADR, and enquiry management.

Shanzé is a member of the Attorney General’s Junior Junior Panel and has appeared in court unled. She recently completed a secondment in the private wealth and tax team of a leading private client law firm (2025). Prior to specialising in tax, she gained experience at the Government Legal Department and in legal environments in China, India, Canada, and Greece.

She is a member of the Revenue Bar Association and the Chancery Bar Association, accepts instructions in all areas of tax law, and is qualified to accept instructions directly from the public.

She is also an Associate Lecturer at Goldsmiths University, teaching Media and Ethics Law.