Tax Dispute Resolution: Advised clients of the firm in respect of a large number of tax disputes and tax litigation. These include disputes on outbound and inbound structures, transfer pricing, Part IVA and other anti-avoidance provisions, capital gains, royalty taxation, insurance contracts, permanent establishment and business profits and evidentiary matters.
Mergers and Acquisitions: Advised on numerous large-scale mergers and acquisitions. These include acting as lead tax advisor for Smorgon Steel Group in respect of its acquisition by OneSteel and divestments of assets to BlueScope Steel, which was the largest steel industry restructure in Australia and numerous industry-specific acquisitions of local assets and entities by multinational groups.
International Taxation: Advised on inbound and outbound structures, mainly in respect of tax treaties, attribution provisions and transfer pricing. These include large-scale infrastructure and telecommunication projects, intellectual property based arrangements and the establishment of local and foreign headquarters and structures. Industries include construction, finance, manufacturing, defence, pharmaceutical, software development, hardware distribution and confectionary.
Broader Tax Advice: Advised on a broad range of general taxation issues including restructuring, capital gains tax, indirect taxation, anti-avoidance provisions, advice to insurance providers on tax insurance policies, research and development concessions, succession planning, philanthropic arrangements, revenue and capital assets, intellectual property issues, asset divestment and indirect taxes.
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