Rimma Miller
Clayton Utz
Rimma has 25 years' experience in resolving taxation disputes, both at early stages of audit and reviews all the way through to litigation. Rimma is an experienced advisor and tax litigator. She conducts tax and tax-related litigation, both at federal and state levels. Rimma also has experience in conducting judicial review, administrative law matters, constitutional law matters, debt litigation and insolvency matters.
Rimma's tax controversy practice is founded on providing objective and strategically sound advice and risk assessment at all stages of tax controversy, and taking a strategic, balanced approach to taxation matters whether she is representing public or private sector clients or the ATO.
Rimma is committed to minimising tax disputes for major projects by providing preventive tax risk management and governance solutions and works with clients to establish efficient and cost-effective ways to resolve or manage tax disputes.
** Notable reported litigation matters: Successfully acted as an instructed solicitor in a large number of strategic large scale tax litigation matters, including:
Geocon Land Holdings No 5 Pty Ltd v Commissioner of Taxation [2025] FCAFC 172
Commissioner of Taxation v PepsiCo Inc [2025] HCA 30; [2024] FCAFC 86; [2023] FCA 1490
KBHN v Commissioner of Taxation [2025] 1875; [2025] ARTA 970
BHMH v Commissioner of Taxation [2025] ARTA 996
Commissioner of Taxation v Rawson Finances Pty Ltd (costs) [2024] FCA 19
Sibai v Commissioner of Taxation [2021] FCA 1353
Mussalli v Commissioner of Taxation [2020] FCA 544; [2021] FCAFC 71
Crown Resorts v Commissioner of Taxation [2020] FCA 1295
Origin v Commissioner of Taxation (No2) [2020] FCA 409
RCF IV LP v Commissioner of Taxation [2018] FCA 41
Oswal v Commissioner of Taxation [2013] FCA 745; [2015] FCA 1439; (No2) [2015] FCA 1143; (No 3) [2015] FCA 1394; (No 4) [2016] FCA 666
Blank v Commissioner of Taxation [2014] FCA 87; (No 2) [2014] FCA 517; [2015] FCAFC 154 [2016] HCA 42
RCF III v Commissioner of Taxation 2014 (special leave application)
** Advice and representation at ATO reviews, audits and objections: Regularly assists clients in large corporate and high wealth space to manage and successfully resolve ATO audits and reviews. Some of Rimma's recent client engagements:
Advising a multinational technology company in relation to a transfer pricing audit.
Advising a top multinational energy and resources company in relation to an audit by the ATO, covering capital gains tax and anti-avoidance issues.
Representing the beneficial owners of a large cross boarder technology company in ATO audit with the focus on the issues of residency, related party dealings and transfer pricing, including preparing responses to and dealing with extensive requests for information.
Advising the client in relation to a large matter involving a transfer of intellectual property offshore and raising the issues of transfer pricing and anti-avoidance.
Advising and representing a large privately owned building and construction group in their claim of professional negligence against a large professional services firm, achieving a successful resolution out of court.
Representing a multinational life sciences company in relation to a transfer pricing audit and objection and successfully resolving the dispute through settlement.
Representing an ASX top 100 financial services and insurance client in CGT audit conducted by the ATO and successfully resolving the dispute through settlement.
Representing a large multinational energy and resources company in relation to two audits by the ATO in relation to capital gains tax and successfully resolving the matters by settlement.
Advising a high wealth client to assist with negotiating the unwinding of a past complex transaction that was of significant concern to the ATO and subject to the ATO action. Reaching agreement with the ATO as to the best form of transaction suitable to our client.
** Experience gained prior to joining Clayton Utz