Charles Suttie
Clayton Utz
Charles has 16 years' experience in the strategic resolution of tax disputes for a range of clients, from high net worth individuals to multi-national corporations. Charles has also had the opportunity to represent the Australian Taxation Office in a number of strategic tax matters.
Charles is an experienced tax advisor, providing advice and representation in the early stages of disputation and an experienced litigator in federal and state courts and administrative tribunals. Charles assists clients in a wide range of tax related disputes ranging from matters involving transfer pricing, anti-avoidance and consolidation to matters involving trusts, capital gains and offshore income.
In addition, Charles has represented clients in tax-adjacent matters such as the judicial review of administration action, asset freezing orders and the ATO's powers to access premises. Clients in the earlier stages of tax reviews, audits and objections benefit from Charles' depth of experience in resolving disputes during those processes.
In his approach, Charles focuses on providing practical, strategic advice aligned with the outcomes sought by the client.
Many matters have been resolved by confidential settlement, but some have proceeded to various stages of litigation. Recent matters include:
Hilton International Australia Pty Ltd v Commissioner of Taxation (judgment reserved)*
KBHN v Commissioner of Taxation [2025] ARTA 1875; [2025] ARTA 970*
BHMH v Commissioner of Taxation [2025] ARTA 996*
Hawkins v Commissioner of Taxation [2017] FCA 1247; 73 AAR 216 (Wigney J)*
Binqld Finances Pty Ltd (In Liq) v Tamarama Fresh Juices Australia Pty Limited; In the Matter of Binqld Finances Pty Ltd (In Liq) [2017] FCA 358; 156 ALD 49 (Foster J)*
BCI Finances Pty Limited (in liq) v Binetter (No 3) [2015] FCA 1336 (Gleeson J)*
12 Years Juice Foods Australia Pty Ltd v Commissioner of Taxation [2015] FCA 741 (Edmonds J)*
Advice and representation in reviews, audits, objections and litigation which resolved:
Assisting clients in managing their relationship with the ATO and responding to ATO formal notices.
Advising a multinational technology company in relation to a transfer pricing audit.
Assisting a high net worth individual to resolve with the ATO a long-running dispute involving international elements.
Gathering evidence to defend a high net worth individual against tax avoidance allegations
Federal Court appeal for a high net worth individual involving carry-forward losses.
* Experience gained prior to joining Clayton Utz