Shanzé Shah
Shanzé is developing a busy and broad-ranging practice across all areas of tax law. She advises on both contentious and non-contentious matters, with particular experience in Inheritance Tax, Capital Gains Tax, Income Tax, VAT, SDLT, domicile and residence, the taxation of charities and trusts, and private client matters including wills.
In 2025, Shanzé completed a secondment in the private wealth and tax team of a leading private client law firm, where she gained valuable experience advising high-net-worth individuals, trustees, and charitable bodies. Prior to specialising in tax, she worked at the Government Legal Department and gained legal experience across multiple jurisdictions, including China, India, Canada, and Greece.
Shanzé is a member of the Attorney General’s Junior Junior Panel and has experience successfully appearing in court unled. She is regularly instructed in advisory work and litigation across a wide range of tax disputes and planning matters, and she accepts instructions in all areas of tax law. She is also qualified to accept instructions directly from the public.
Alongside her practice, Shanzé is an Associate Lecturer at Goldsmiths, University of London, where she teaches Media and Ethics Law. She is a co-author of the forthcoming edition of Taxation of Charities & Nonprofit Organisations, written with James Kessler KC and Etienne Wong. She was also recently recognised as Pro Bono Champion for her consistent volunteering in the CLIPS scheme.
Shanzé is a member of both the Revenue Bar Association and the Chancery Bar Association
Practice Area
Panel
- Contributing Author
Qualified Year
- Call to Bar 2020
Experience
- Government Legal Department (2022 - 2023)
Membership
- Chancery Bar Association
- Revenue Bar Association
- Women in Tax
Qualifications
- LLB (2017)
- LLM (2018)
- BPTC (2019)
Education
- University of Birmingham (2017)
- UCL (2018)
- BPP London (2019)
4 Contributions by Shanzé Shah
PRACTICE NOTES
Overpaid tax restitution: Woolwich and mistake claims, limitation, HMRC defences; VAT section 80 exclusivity, supplier/customer claims and Reemtsma
Practice Note
This Practice Note considers situations where a person has overpaid tax (that is, paid tax that was not in fact due) and their ability to recover that sum under the common law of restitution. It applies to both direct taxes and VAT and addresses the taxpayer’s rights to reclaim such amounts...
Direct taxes
VAT
Overpayments arise for a range of reasons, though a significant number of court cases have concerned tax charged in breach of EU law. A taxpayer should first determine whether they have, or previously had, a statutory route to recover overpaid tax, see Practice Note: Overpaid tax—the statutory regimes. If a statutory right exists, the terms of that legislation may bar a common law restitution claim, even where the statutory claim is now out of time...
This Practice Note cites EU-derived law and case authorities. The UK ceased to be an EU Member State on 31 January 2020. On that date, the UK entered an implementation period (IP) during which, for many purposes, it continued to be treated as a Member State and remained bound by EU law...
Tax
PRACTICE NOTES
Overpaid UK Tax: Overpayment Relief for Direct Taxes, VAT Reclaims under s 80 VATA, Four‑Year Cap, Late Input Claims, Set‑off and Unjust Enrichment
This Practice Note outlines the statutory provisions regulating the recovery of:
overpaid direct tax, for example where a person has remitted income tax that was not actually due; and
VAT paid by a taxable person to HMRC in excess of their liability, whether because too much output tax was accounted for or too little input tax was reclaimed
Where these statutory frameworks do not apply, a potential remedy may arise under the law of restitution. For details on how restitution operates in relation to overpaid tax, see Practice Note: Overpaid tax—restitution. This Practice Note contains references to EU-derived law and case law. The UK ceased to be an EU Member State on 31 January 2020. On that date, the UK entered an implementation period (IP), during which it continued to be treated as a Member State for many purposes and remained bound by EU law. The IP concluded at 11 pm on 31 December 2020. At that point, a body of EU-derived rights and legislation, known as retained EU law (REUL), was converted into domestic UK law...
Tax
PRACTICE NOTES
Overpaid UK tax: repayment interest, restitution and damages (EU law pre‑2021); VAT harmonisation, Littlewoods; and corporation tax on restitution interest
This Practice Note is about:
a taxpayer’s entitlement to interest on refunds of tax paid in excess, whether under a statutory framework, the common law (notably the law of restitution), or EU law, retained EU law, or assimilated law
the corporation tax charge applicable to restitution interest
for tax overpaid before 31 December 2020, the EU law question of whether such overpayments may give rise to a right to damages
This Practice Note cites EU-derived legislation and case law. The UK ceased to be an EU Member State on 31 January 2020. From that date an implementation period applied, during which the UK continued, for many purposes, to be treated as a Member State and remained subject to EU law. The implementation period ended at 11 pm on 31 December 2020. At that point, a body of EU-derived rights and legislation—called retained EU law (REUL)—was converted into domestic UK law. On 1 January 2024, any REUL still in force after the end of 2023 was reclassified as assimilated law...
Tax
PRACTICE NOTES
UK VAT bad debt relief and credit notes: eligibility, calculation, timing, payment allocation, administration, VAT groups, and purchaser input tax adjustments
This Practice Note explains how a taxable person who has declared and remitted VAT on a supply, yet does not receive the price for that supply, can seek a repayment, in full or in part, of the VAT paid. This covers cases where consideration is not in fact received.
There are separate routes depending on the facts:
where, after the time of supply, the supplier agrees to repay or reduce the price charged, the adjustment is dealt with under the credit note rules
where the price remains unpaid (in whole or in part) and the supplier ultimately writes it off as irrecoverable, the claim is addressed under the rules on bad debt relief
This Practice Note focuses mainly on the VAT bad debt framework, but, to set matters in context, it also gives a short outline of the credit note provisions explained above.
EU law
Under Council Directive 2006/112/EC (the VAT Directive), VAT on a supply is due by reference to the taxable amount (or value) of the supply, being everything that forms the consideration received or to be received by the taxable person (from any person) for that supply. The corollary is that VAT is not chargeable on more...
Tax
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