I solve complex multinational tax issues and cross-border operational challenges by combining economic principles, business acumen and data analytics. I also specialise in cross border transactions, structuring deals, tax risk management and in controversy.

Former clients include prominent Australian and foreign owned multinational enterprises and Australian entrepreneurs across a range of sectors including energy and resources, private equity, infrastructure, fast moving consumer goods, automotive, food and beverage, technology, media, retail, e-commerce and financial services.

Career highlights

• Experienced senior team member of an International Tax and Transfer Pricing team at a Big 4 accounting firm
• Several years' experience as an ATO economist, focused on international tax matters and tax data analytics
• Negotiated over 20 Advance Pricing Arrangements, providing clients with certainty on complex international related party dealings and collateral tax issues
• Managed and resolved several complex transfer pricing controversy matters including ATO reviews, audits, settlements and obtaining double tax relief under the Mutual Agreement Procedure article in Australia's tax treaties
• Successfully defended a client's Multinational Anti-Avoidance Law position that was subjected to a detailed ATO review.
• Designed and implemented an intellectual property framework for a large multinational consumer products business
• Conducted analytical assessments of multinational business value chains, including the interpretation of Country by Country Reporting tax data
• Advised on the international tax and transfer pricing structuring aspects of a number of significant Corporate M&A and Private Equity transactions, both pre and post-acquisition
• Managed Foreign Investment Review Board tax conditions relating to regulatory review of shareholder debt arrangements and post-merger supply chain integrations
• Provided in-house transfer Price thought leadership and training sessions to prominent multinational groups
• Acted as guest lecturer at the University of Melbourne for students studying "Transfer Pricing Practice and Problems".

*not an Australian legal practitioner

• Federal Budget 2024/25 Highlights
  

  The Government's Budget forecasts a budget surplus in the 2023-2024 year, followed by larger deficits than expected across the next 4 years.

• The hidden transfer pricing risks of your global ESG strategy
  

  Whilst ESG initiatives become increasingly commonplace, the associated transfer pricing considerations can often lag behind. This can have significant implications on a company's global transfer pricing position and expose corporates to significant financial exposures and tax liabilities.

• OECD Base Erosion Profit Shifting Pillar Two initiatives - Australian Perspectives
  

  MinterEllison's Transfer Pricing team share their insights into the OECD Base Erosion Profit Shifting Pillar Two initiatives with Bloomberg Tax.

• Glencore decision limits transfer pricing reconstruction powers
  

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

• Tax updates to proposed intangibles integrity measure
  

  Updates to the proposed tax reform measures preventing multinationals from claiming Australian tax deductions for certain payments made for the use of intangible assets to foreign associates in low-tax jurisdictions.

• MinterEllison intensifies ‘whole of firm’ offer in response to client demand in national business, construction, and tax environments
  

  MinterEllison announced two high profile lateral appointments to strengthen the firm’s offer in the key sectors of international tax, and construction & property advisory.

• 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 guidance on the arm's length debt test and interest free loans between related parties
  

  The ATO recently provided updated guidance on the arm's length debt test (TR 2020/4 and PCG 2020/7) and issued the draft Schedule 3 outlining factors modifying a risk score for interest free loans between related parties, to be added to PCG 2017/4DC2.

• A 'thin new world' part 2 – proposed changes to Australia's thin capitalisation provisions
  

  Under proposed new law, organisations may be limited in their ability to claim debt deductions from 1 July 2023.

• A 'thin' new world - Proposed changes to Australia's thin capitalisation rules
  

  Under proposed new law, organisations may be limited in their ability to claim debt deductions from 1 July 2023.

• 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.

• New public country-by-country reporting rules
  

  Large multinationals with an Australian presence may be required to publicly report key tax information.

• MinterEllison Australia awarded Transfer Pricing Firm of the Year at ITR’s ASIA TAX AWARDS 2020
  

  Tax practice shortlisted in six categories overall