My clients know me for my resolution mindset, focussed on achieving commercial and practical outcomes in what are often complex tax disputes. With an increased focus on prevention, I also work with clients to engage with the Australian Taxation Office (ATO) in real time on high profile and sensitive transactions to prevent future contention.

My unique experience spans twenty years, acting for both taxpayers and the ATO across all forms of ATO activity from audits and risk reviews through to litigation. During my time as a Deputy Commissioner at the ATO, I was in charge of the ATO's litigation and dispute resolution segments. With that experience I am uniquely placed to advise clients on how to present cases to the ATO to promote early and favourable outcomes whilst also preserving ATO relationships.

I work with a wide variety of clients from multinationals and large Australian corporations through to private companies, family offices and high wealth individuals managing sensitive issues with the ATO.

Career highlights

• Former Deputy Commissioner at the Australian Taxation Office responsible for all objections (appeals) and litigation. In this role I advised and played a senior role in significant litigation involving the ATO from 2016 to 2021.
  Assisted numerous multinational clients with complex transfer pricing and corporate tax issues at audit and objection stages, including assistance with responding to information requests, preparation of evidence, attendance at interviews and successful execution of settlement negotiations.
• Assisted various high net worth individuals in relation to audits involving corporate tax including Part IVA, debt recovery and negotiation of favourable settlement outcomes.
• Representing clients before the ATO's general anti-avoidance panel, including assistance with case preparation and advising on the application of Part IVA and other anti-avoidance rules.
• Assisted clients across multiple sectors with indirect tax disputes, including appearance as instructing solicitor or counsel in numerous cases. This includes the following publicly reported cases: ECC Southbank v FCT [2012] FCA 795; Qantas v FCT [2011] FCAFC 113; Luxottica Retail Australia Pty Ltd [2011] FCAFC 20; Lansell House Pty Ltd v FCT [2011] FCAFC 6; LeasePlan Australia Limited v FCT [2009] FCA 1309; Department of Transport v FCT [2009] FCA 1209.
• Acted as instructing solicitor and barrister in numerous other significant tax matters in the Federal Court of Australia, State Supreme Courts and High Court of Australia in relation to most aspects of federal tax law including income tax disputes, R&D concessions and superannuation as well as payroll tax at the state level.

• Good things come to those who wait
  

  This article focusing on the three most relevant to public and multinational businesses of many specific insights presented.

• 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.

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  The Commissioner has appealed the AAT's ruling that an unpaid present entitlement does not constitute a loan under Division 7A of the ITAA36.

   

• 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.

• What you missed in the ATO's annual report – how to successfully resolve a tax dispute
  

  We analyse the ATO's recent annual report, considering statistics of various ATO programmes in the report to provide readers with insights into ATO activity and behaviour.