As the firm often represents the Australian Taxation Office (ATO), our private sector clients are offered an unparalleled depth of experience and unique perspective.

My work is based on 25 years' experience managing all manner of ATO compliance enquiries, including early engagements, risk reviews and audits, as well as some of the most significant tax litigation in Australia.

I am recognised for my ability to engage and influence the ATO on behalf of my clients, to reach satisfactory conclusions to any tax controversy or dispute.

Career highlights

ATO matters

• Represented large corporates and high-wealth individuals, as well as the ATO
• Conducted or was responsible for the most significant tax cases in the Federal Court and High Court of Australia, especially in relation to tax avoidance and transfer pricing
• Advised the ATO on transfer pricing cases and large transfer pricing audits
• Acted as MinterEllison’s ATO client relationship partner, responsible for managing all matters conducted on behalf of the ATO, especially taxation appeals and complex debt recovery matters conducted nationally in the Federal Court, the Administrative Appeals Tribunal (AAT), the High Court and various state supreme courts
• Represented the Deputy Commissioner of Taxation in complex, high-profile recovery proceedings in Australia and overseas jurisdictions
• Managed and conducted early neutral evaluations in major complex tax disputes
• Advised the ATO on exercising access powers in various circumstances, including how to respond to claims for legal professional privilege
• Chevron Australia Holdings Pty Ltd v Commissioner of Taxation – acted in Federal Court proceedings related to intra-group loans and transfer pricing
• Deputy Commissioner v Philip Whiteman & Ors – advised on a matter involving illegal ‘phoenix’ activity, including applications to appoint provisional liquidators and wind up related companies on just and equitable grounds, and applications for freezing orders
• Haritos v Commissioner of Taxation; Confidential v Commissioner of Taxation – acted on behalf of the Commissioner, with a successful outcome in AAT and Federal Court proceedings
• Mitsui & Co (Australia) Ltd v Commissioner of Taxation – represented the Commissioner, obtaining favourable decisions in Federal Court proceedings and before the Full Federal Court
• Federal Commissioner of Taxation v Spotless Services Ltd – appeared in a significant decision in relation to the non-inclusion of assessable income, resulting in significant clarification of the law
• R & M Gashi v Commissioner of Taxation; Howard v Commissioner of Taxation – advised the ATO in significant Federal Court and Full Federal Court proceedings, and High Court appeals

Private sector matters

• Worked with high-wealth individuals and large corporates, including large financial institutions, on overall tax risk management strategies
• Conducted large transfer pricing audits on behalf of telecommunications, automotive, energy and resources, and infrastructure corporations
• Facilitated early ATO engagements on behalf of large infrastructure, industrial chemicals and retail corporations, to achieve tax certainty on rulings and manage risk review audits

Recognition

• Listed in Legal 500 as a leading individual in 2017

Education
LLB

• Member, Law Institute of Victoria - Administrative Law Section
• Member, Taxation Institute of Australia
• Member, Law Council of Australia

• Glencore decision limits transfer pricing reconstruction powers
  

  We provide an overview of the federal court's decision between Glencore and the Commissioner of Taxation.

• Federal Court's decision on awarding indemnity costs
  

  Federal Court exercises discretion to award indemnity costs in a fixed amount sought by the Commissioner of Taxation.

• Landmark decision confirms that legal professional privilege offers no protection against data leaks
  

  The High Court has affirmed in Glencore that legal professional privilege is not an actionable legal right capable of attracting relief, but rather, provides immunity from the exercise of power that would otherwise compel the disclosure of privileged documents.

• AAT clarifies Commissioner's power to review R&D eligibility
  

  Administrative Appeals Tribunal confirms Commissioner of Taxation's authority to assess or make decisions regarding eligibility of taxpayers registered R&D activities.

• The Superannuation Guarantee Gap
  

  On 29 August 2017, the ATO announced the results of research it conducted into 'the superannuation guarantee gap'. This superannuation guarantee gap is an estimate of the difference between the amount of superannuation guarantee contributions made and the amount of superannuation guarantee contributions required to be made.

• Understand when you may be at risk of an ATO enquiry
  Shredding files and heading to the Cayman Islands won't save companies or high wealth individuals from the Australian Taxation Office (ATO) detecting offshore activities and potential tax avoidance.
• ATO's revised ruling on software distribution arrangements
  

  ATO has released its revised draft ruling TR 2024/D1 concerning whether payments in software distribution arrangements may be characterised as royalties, with royalty withholding tax implications.

• ATO reviewing trust income reduction arrangements
  

  On 17 November 2016, the ATO released Taxpayer Alert TA 2016/12, which deals with trust income reduction arrangements under review by the ATO. The Alert highlights the ATO's increasing concern with some trust arrangements. MinterEllison provides commentary and an overview on the Alert.

   

• ATO issues finalised PCG on Intangibles Migration Arrangements
  

  The ATO has released Practical Compliance Guideline 2024/1 Intangibles Migration Arrangements for immediate application, with key changes to earlier draft guidance.

• Under review: the ATO's renewed focus on private groups
  

  The ATO is devoting significant resources to assuring the tax and superannuation obligations of private groups, including small to medium enterprises, family offices and high net worth individuals.