Philip Bisset

Partner Brisbane, Perth

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Overview

Philip is a key specialist tax adviser to energy and resources companies, combining tax advice in all facets of revenue law (including taxation, stamp duty, GST and Petroleum Resource Rent Tax) with acting for clients in tax disputes.

Previously a partner in "big four" accounting firm and in-house with Exxon and Rio Tinto, Philip has a strong practical knowledge of major facilities (such as oil platforms and gas plants). He works closely with corporate tax teams to structure the tax aspects of inbound and outbound investments, and devise tax dispute resolutions that are robust and commercial. He has a specialist knowledge of the Petroleum Resource Rent Tax and is one of few tax lawyers to have worked with clients continuously on the impact of the PRRT since its introduction in 1990.

Notable Work

Confidential resources client: advising on the income tax, duty and GST aspects of settlement of a dispute over ownership of significant resources project.
Large US/Canadian miners: acting in a confidential matter before the Federal Court on capital gains consequences the sale of a minority holding in a large Australian mining holding. This ongoing case involves complex valuation and treaty issues.
Various non-resident investors: acting as instructing solicitor in the Federal Court at first instance and on appeal to the Full Court and High Court for landmark cases involving the interpretation of international tax treaties and the taxation of the disposal of shares by a non-resident in Australian companies.
Office of State Revenue: advised on a number of matters relating to payroll tax disputes regarding the grouping of taxpayer entities for payroll tax purposes. There were excellent results in the matters.
Resource Capital Funds III, IV and V LP v Commissioner of Taxation: acting as instructing solicitor in the Federal Court at first instance and on appeal to the Full Court and High Court for landmark cases involving the interpretation of international tax treaties and the taxation of the disposal of shares by a non-resident in a mining company.
Confidential resources client: assisted with negotiating and structuring government assistance for a major Australian refinery development.

Philip Bisset

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