Practice Expertise
- Projects and project finance
- Tax controversy
- GST
Areas of Practice
- GST
- Projects and project finance
- Tax controversy
- Tax
Profile
I'm a trusted advisor to a number of large multinational and ASX-listed corporate groups. In addition, I routinely act for the ATO, having instructed in a number of significant cases, regularly presenting and facilitating workshops, assisting with preparing public tax rulings, and advising on formal access powers.
I also draw on my qualifications as a Chartered Accountant and Chartered Tax Advisor, to provide holistic commercial and strategic advice to my clients.
Career highlights
- Managed some of the largest tax audits in Australia for listed and multinational corporate taxpayers and large private groups.
- Instructing solicitor in various tax cases, recent highlights including: Victoria Power Networks v FCT, Song v FCT (No. 1), Anna Paule & Others v FCT, PKWK v Innovation and Science Australia and Deputy Commissioner of Taxation v A&S Services Pty Ltd.
- Achieved excellent outcomes in settlement meetings and alternative dispute resolution, having instructed and appeared in mediations, independent conciliations, independent binding determinations and early neutral evaluations, having received accreditation at the Australian Advocacy Institute.
- Advised and attended GAAR Panel hearings, ATO independent reviews, test case funding applications, formal interviews and ATO in-house conciliations.
- Prepared numerous private ruling applications, objections and responses to position papers that have resulted in favourable outcomes.
- Assisted the ATO with redrafting model settlement deed and the preparation of public rulings and interpretative decisions.
- Achieved substantial and full remission of interest and penalty amounts pursuant to Part IVC and Administrative Decisions (Judicial Review) Act 1977 appeals (of amounts in excess of $1 million).
Areas of Practice
- GST
- Projects and project finance
- Tax controversy
- Tax
Professional Career
Articles
- 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.
- Medical practices and payroll tax: the current state of play
Medical practices that engage practitioners as contractors need to urgently review their payroll tax position due to recent revenue office rulings.
- 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.
- 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.
- Tangible consequences for SGEs: Proposed changes to intangible asset exploitation in low-corporate tax jurisdictions
Australian Treasury proposes new rules to limit significant global entities from claiming deductions for payments made to associates in low corporate tax jurisdictions related to intangibles from 1 July 2023.
- Recent cases: employment agency contract provisions in the Payroll Tax Act 2007 (NSW)
Two recent decisions in the Supreme Court of NSW assist in confirming the scope of the problematic 'employment agency contract' provisions in the Payroll Tax Act 2007 (NSW).
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