PBL/CVC restructuring: Acting for the financiers in relation to the PBL/CVC restructuring of media assets into joint venture vehicle. This was one of the major transactions of the past year in this sector. Tax advice centred on international issues, especially withholding tax, ensuring that the financing was effected in a tax efficient manner.
Barrick Gold Corporation: Acquired and has proceeded to integrate the Placer Dome regional assets into its Australian operations. The acquisition made Barrick the largest gold mining company in the world. We provided tax advice to Barrick on complex integration issues such as tax consolidations and capital gains tax.
Pacific Equity Partners: Provided taxation advice to Pacific Equity Partners in relation to the largest private equity fund in Australia. This included advising on tax structuring and international aspects of the fund.
Roche Products Pty Ltd: Acted for the taxpayer in Roche Products Pty Ltd v Commissioner of Taxation, which is the only transfer pricing dispute to be brought to a final hearing for more than 20 years and achieved a favourable outcome.
Macquarie Bank: Advised Macquarie Bank on the establishment of a pastoral fund which aims to attract over $200 million from the wholesale superannuation industry to buy large-scale sheep and cattle properties. This is the first pastoral fund on this scale that is being marketed globally.
Government department: Advised a government department in relation to a development, including advice on GST leakage, submission of ruling requests to the ATO and provision of detailed advice regarding management of GST compliance for the department and its contractual counterparties.
Capital raising: Developing a highly efficient international investment product to facilitate raising capital in the US, Europe and Asia for investment globally across several asset classes. The efficiencies included management of complex accruals taxation, foreign exchange issues and potentially material withholding tax leakages.