JERN-FEI NG

Advised and acted for the taxpayer in a number of VAT, IPT and
duties cases, including:
• American Express Services Europe Ltd v Commissioners for
Revenue and Customs. Acted for American Express in a partial
exemption special method dispute. Commissioners withdrew their
case during the course of the substantive hearing.
• BlackRock International Ltd v Commissioners for Revenue and
Customs. Instructed for BlackRock in claims for recovery of
compound interest from HMRC.
• Birkdale School, Sheffield v Commissioners for Revenue and
Customs. Appeared for Birkdale School in single/multiple supplies
case concerning tuition fees which was decided by the Chancery
Division in favour of the school.
• Chubb Insurance Company of Europe SA v Commissioners for
Revenue and Customs. Acted for Chubb in a dispute concerning
the method of apportionment for IPT. Commissioners withdrew
their case following the service of witness statements.
• Gold Digit Ltd v Commissioners for Revenue and Customs.
Instructed for taxpayer in dispute concerning whether best
judgment was used in the raising of assessments. Commissioners
withdrew their case shortly before the substantive hearing.
• Livewire Telecom Ltd v Commissioners for Revenue and
Customs. The first substantive MTIC fraud appeal that was heard
by the Chancery Division. Represented the taxpayer successfully
in proceedings before the VAT Tribunal and on appeal.
• Olympia Technology Ltd v Commissioners for Revenue and
Customs. Acted successfully for the taxpayer in a dispute
concerning the recoverability of costs. Commissioners withdrew
their case prior to the substantive hearing.
• Queen’s College, Oxford and others v Commissioners for
Revenue and Customs. Currently acting for 15 Oxford colleges in
their claim for recovery of compound interest from HMRC.
• R (on the application of Lloyds TSB) v Commissioners for
Revenue and Customs. Instructed for Lloyds TSB in judicial
review concerning an extra-statutory concession which had been
made by HMRC.
• RBS Deutschland Holdings GmbH v Commissioners for Revenue
and Customs. Acted successfully for an RBS subsidiary before the
VAT Tribunal in an abuse of right case. Acted also in the
subsequent reference to the ECJ. ECJ judgment pending.
Reported Cases • Fiona Trust & Holding Corporation v Privalov [2006] All ER (D)
254 (Oct).
• Olympia Technology Ltd (2006) VTD 19984
• Fiona Trust & Holding Corporation v Privalov [2007] 1 All ER
(Comm) 81
• Nikitin v Richards Butler LLP [2007] All ER (D) 129 (Feb).
• DDT Trucks of North America Ltd v DDT Holdings Ltd [2007] 2
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