I have primarily acted for clients in the energy & resources, pharmaceuticals, software and gambling industries.

I have acted for and against the ATO in tax litigation in the High Court of Australia, Federal Court of Australia and Administrative Review Tribunal.

In addition to my experience at MinterEllison:

• I worked in-house at one of Australia's largest taxpayers, gaining practical experience in managing ATO relationships from an in-house perspective; and
• was seconded from MinterEllison to the ATO's review and dispute resolution group, gaining insights into ATO decision making processes.

Career highlights

• Advising multiple clients on the resolution of significant ATO disputes via settlement;
• Acting in the landmark PepsiCo, Inc v Commissioner of Taxation case which considered Australia's royalty withholding tax rules, Diverted Profits Tax rules and complex issues relating to intangibles;
• Advising a global resources company (USD$40B+ revenue) on a high-priority ATO dispute involving intercompany finance transactions, including resolution of the dispute via settlement;
• Advising a global pharmaceutical company in a multi year transfer pricing dispute with the ATO, including advising on mutual agreement procedure (MAP) / arbitration mechanisms and achieving resolution of the dispute via settlement;
• Advising global gaming and gambling companies in ATO reviews and audits;
• Advising on matters involving complex intellectual property valuation issues;
• Advising on the potential application of debt deduction creation rules.

• Division 142 passing on clarified by the Full Court - win for the taxpayer
  

  MinterEllison are pleased to have acted for the taxpayer, Geocon whose appeal was allowed by the Full Court, providing guidance on the question of passing on under Division 142.