image of Cameron ForbesCameron Forbes

Clayton Utz Special Counsel , Melbourne T +61 3 9286 6311

As a corporate tax lawyer, Cameron Forbes advises on income tax, stamp duty, and GST in the context of large corporate transactions, including providing tax advice and drafting tax clauses for some of the largest and most complex Australian corporate transactions in recent years.

Cameron spent two years of his career working as an M&A lawyer, which gives him a nuanced understanding of – and invaluable insight into – the commercial realities of large-scale corporate transactions. Further it positions him to assist with drafting tax provisions in M&A transaction documents, and to provide tax structuring advice on all areas of corporate tax, with a particular focus on income tax.

Before joining Clayton Utz, Cameron worked at another top tier firm, and in the legal division of the State Revenue Office Victoria which, together with his strong links with the Australian Taxation Office, means he is well placed to liaise and negotiate with tax authorities.

Cameron also holds Chartered Accountancy qualifications which he draws upon when advising on any tax issues that arise on commercial transactions.

His practical knowledge of corporate tax topics sees Cameron regularly called to present at various seminars and conferences, including most recently for the Tax Institute of Australia, Legalwise Seminars and the Law Institute of Victoria.

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General tax advice

Alcoa: Cameron provided Alcoa with income tax and GST support in respect of a high-value and complex transaction (including preparing tax advice, tax drafting and ATO ruling applications).

ISPT Super Property: Cameron provided ongoing tax advice for various matters in respect of ISPT’s property portfolio around Australia.

Chevron Group: Cameron provided tax support to the Chevron Group for a number of commercial transactions and matters in Australia.

Toyota: Cameron assisted Toyota with various corporate tax matters (including employment tax in respect of its Australian operations)

Minderoo Group: Cameron provided ongoing tax support to:

  • the commercial arm of the Minderoo Group for various corporate transactions, including the acquisition of the historical Indiana Tea House at Cottesloe Beach, Western Australia; and
  • the charitable arm, including providing pro-bono advice for the establishment of the $70m "Minderoo Fire Fund" to support communities affected by the 2019/2020 Australian bush fires.

DHL Group: Cameron assisted the DHL Group with income tax, GST and stamp duty advice on a recent transaction. This included structuring advice to ensure compliance with broad and complex new stamp duty provisions enacted in the relevant transaction jurisdiction.

Royal Automobile Club of Victoria: Cameron assisted with tax support on various corporate transactions related to its business.

Marriot Group International: Cameron provided income tax advice on certain payments made by an offshore entity of the Marriot Group International to Australian employees.

Mergers and acquisition

Glencore: Cameron provided tax support to Glencore on a number of its corporate transactions, including the $AU65bn merger with Xstrata.

Saputo: Cameron advised leading global dairy group Saputo in a number of its recent corporate transactions, including its AU$1.3bn acquisition of the co-operative company Murray Goulburn, Australia's biggest milk processing company in 2018; the $250m disposal of a processing facility in Koroit to Bega and Saputo's $280m acquisition of the King Island Dairy business in 2019. For example, the acquisition of the co-operative company Murray Goulburn involved advice on all tax aspects of the acquisition structuring and post-acquisition restructuring and associated transactions.

GFC Alliance (Liberty House and SIMEC): Cameron provided tax advice in its acquisition of Arrium Australia out of administration.

Myer: Cameron provided tax support for Myer’s acquisition of the Marcs clothing and fashion business.

Hanson Group: Cameron provided ongoing tax support on various matters related to its global leading cement, concrete and heavy building products business.

Tox Free Solutions Limited: Cameron acted for Tox Free Solutions Limited in relation to a scheme of arrangement under which it was acquired by a subsidiary of Cleanaway Waste Management Limited.

Construction and Major Projects

West Gate Tunnel: Cameron provided tax support (including tax review and drafting of the relevant transaction documents) to the State of Victoria on the high-value West Gate Tunnel project.

North East Link: Cameron provided tax support to the State of Victoria in respect of the multi-billion dollar North East Link project.

Melbourne Airport Rail: Cameron is providing tax advice on a number of specific matters related to the project.

Banking and Finance

$1b Notes Issuance: Cameron provided tax support on a recent AU$ 1bn notes issuance, including preparing the various documentation to support the satisfaction of the "public offer test" for the purposes of the section 128F withholding tax exemption.

$5b Syndicated Facility: Cameron provided tax support on a AU$ 5bn cross-border syndicated facility for a multinational resources entity, including advising on the associated conversion of the relevant Australian tax consolidated group into a multiple entry consolidated group.

Corporate Bond and Debt Syndications: Cameron advised various lenders and borrower on the Australian income tax implications of a broad range of cross-border corporate bond and debt syndication transactions

Securitisation: Cameron has acted for various financial institutions and borrowers on many securitisation transactions. His work has included preparing tax drafting for transaction documents and tax opinions.

Real Estate

Real Estate Acquisition by listed investment management entity: Cameron gave tax advice on the acquisition of Australian real estate by a listed investment management entity, covering GST, stamp duty and the income tax treatment of distributions by a managed investment trust

Masters Home Improvement Exit: Cameron advised on the Woolworths Group's exit of its investment in the Masters Home Improvement business in Australia, which included related real estate tax issues.

Villawood Properties (incorporating Sandhurst Capital): Cameron assisted Villawood with the tax implications of a number of ongoing real estate matters related to its property development projects.

Cadence Property Group: Cameron provided tax support for various projects related to Cadence’s development and investment management business, including preparing a GST private ruling application in respect of a complex GST issue.

See Taxation

Taxation Disputes

Cameron has advised clients in a number of income tax disputes with the Australian Taxation Office, including disputes over:

  • the deductibility of labour costs related to the construction of capital assets;
  • transfer pricing, and
  • “permanent establishments”.

See Taxation Disputes


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