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Andy Bubb

Special Counsel Melbourne
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+61 431 353 325
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You provided excellent service in resolving a very complex and lengthy dispute with the ATO, adding material value and agreeing the tax attributes of the investment going forward. We really appreciated your support.

– Client

Overview

As a tax lawyer, Andy focuses on resolving complex disputes, particularly for large multinationals. His expertise spans Federal and State-level tax matters, with a focus on contentious international tax and transfer pricing matters. He has wide experience in ATO dispute processes, having represented clients in various ATO processes and successfully negotiated settlements.

Notable Work
  • Confidential client: advising one of the world's largest companies on the ATO's investigation of a treaty shopping issue.
  • Infrastructure client: advising on a complex ATO audit of an Australian infrastructure asset owned by foreign pension and sovereign wealth funds, addressing GAAR and transfer pricing concerns.
  • Entertainment client: advising an ASX-listed client on tax implications of disposing of its UK business.
  • Gig economy client: advising on parallel investigations by state revenue offices and the ATO about whether the client's workforce were employees or contractors.
  • ENR client: advised on a multifaceted ATO audit relating to the income tax and transfer pricing implications of two global restructures.
  • Investment fund client: advising on an ATO audit of relating to whether capital gains tax (CGT) applied to a share sale, which depended on whether the shares were taxable Australian real property (TARP).
  • Automotive client: advising on a multinational automotive client's restructure, including the general anti-avoidance rule (GAAR) and income tax issues.
  • Private equity client: negotiating tax payment deferrals for a portfolio of companies owned by a private equity firm due to COVID-19-related cash flow issues.
  • Sporting client: advising a national sporting code on a landmark transaction to maintain its income tax-exempt status.
  • TTDB v Commissioner of Taxation: review by the Administrative Appeals Tribunal for an individual client about the personal income tax outcomes from various transactions (eg. loans) with related companies.
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