image of Angela WoodAngela Wood

Clayton Utz Partner , Melbourne T +61 3 9286 6181 https://www.claytonutz.com

Angela is a leading tax dispute resolution and litigation lawyer, bringing an exceptional track record of success over 20 years’ dedicated practice in the field. She focuses on proactive, efficient and early resolution of disputes, advising multinational and large domestic corporates, private groups and high net wealth individuals.

Angela advises clients at all stages of tax disputes, from early regulator engagement at transaction, through reviews, audits, independent review, GAAR panel and objections. Angela also has deep tax litigation experience, having run significant Federal, State and High Court matters for both the Commissioner of Tax and for taxpayers.

She is known for her strategic and practical advice, her depth of relationships with the ATO and ability to strike the right balance between robust representation for taxpayers and maintaining productive working relationships with revenue regulators to achieve the best results.

Prior to joining Clayton Utz, Angela was both the National Lead Partner and ASPAC Regional Lead Partner for Tax Controversy at KPMG Law.

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Expertise

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Taxation 

Automotive client: Angela advised on the tax implications of a restructure undertaken by the Australian operations of a multinational automotive client, particularly in relation to the general anti-avoidance rule (GAAR) and other income tax issues. 

Entertainment client: Angela advised on the tax implications of an entertainment client winding up certain offshore operations, particularly in relation to the general anti-avoidance rule (GAAR) and the CGT participation exemption. 

Resources client: Angela advised on the FIRB process from a tax perspective in relation to the client's proposed restructure and refinancing transactions, including in relation to general anti-avoidance rule (GAAR) issues.

Private equity client: Angela negotiated the deferral of tax payments for a portfolio of companies owned by a private equity firm due to significant cash flow issues arising in early to mid-2020 as a consequence of COVID-19, including dealings with the ATO and state revenue offices.

See Taxation

Taxation Disputes

Confidential matter: Angela acted for foreign private equity fund in early engagement process with ATO re: divestment in Australia (residency, source, security of funds for ATO) to successfully avoid dispute.

Confidential matter: Angela acted for multinational commodities business in significant ATO audit (Part IVA/transfer pricing), resolved all issues prior to audit conclusion.

Infrastructure client: Angela advised on an intensive and complex ATO audit of a stapled structure following the ATO's issuance of Taxation Alert 2017/1 regarding its concerns about stapled structures generally. Key issues included the proposed application of the general anti-avoidance rule (GAAR) and the transfer pricing legislation. The matter involved preparing for declaratory relief proceedings (ultimately not required) and appearances at the ATO's GAAR and Independent Review panels.

Resources client: Angela advised on the ATO audit of two internal restructures undertaken by a multinational resources client with operations on several continents. Key issues included the ATO's proposed application of the general anti-avoidance rule (GAAR), the multinational anti-avoidance law (MAAL) and the transfer pricing legislation.

Confidential matter: Angela acted for the Commissioner of Taxation in a significant mediation in relation to a landmark transfer pricing dispute.

Confidential matter:  Angela successfully resolved a significant transfer pricing dispute for a technology company.

Confidential matter:  Angela resolved disputes regarding the application of the Multinational Anti-Avoidance Law in relation to several technology companies.

See Taxation Disputes

Litigation and Dispute Resolution

Angela has conducted many significant tax litigation matters in the AAT, Federal Court, State and Territory Supreme Courts and High Court of Australia, including:

  • Commissioner of Taxation v Spotless Services Ltd (High Court - Part IVA)
  • Sun Alliance Investments v Commissioner of Taxation (Federal Court & High Court - capital gains tax)
  • R & M Gashi v Commissioner of Taxation (Federal Court - default assessments / onus of proof) 
  • Eastern Nitrogen Limited v Commissioner of Taxation (Federal Court - Part IVA)  
  • On Call Interpreters & Translators Agency Pty Ltd v Commissioner of Taxation (Federal Court - employee v independent contractor) 
  • Esso Australia v Commissioner of Taxation (Federal Court - deductibility of exploration, prospecting, tenement acquisition & bid evaluation costs) 
  • Hance & Hannebery v Commissioner of Taxation (Federal Court - outgoings/receipts re: investment in managed investment scheme) 
  • Howard v Commissioner of Taxation (Federal Court & High Court - income tax) 
  • Royal & Sun Alliance Insurance Australia v Commissioner of State Revenue (VIC) (Supreme Court of Victoria - stamp duty) 
  • Lansell House Pty Ltd & Perfek Pty Ltd v Commissioner of Taxation (Federal Court - GST)
  • Capital Club Pty Ltd v Commissioner of State Revenue (Vic) (Supreme Court of Victoria - land tax)
  • Commissioner of Taxation v Secretary, Northern Territory Revenue Office (Supreme Court of Northern Territory - mineral royalty) 
  • Tasmanian Electro Metallurgical Co v Collector of Customs (AAT- diesel fuel rebate) 

Knowledge

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