All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

Australia

Paul McCartin

mccartin-paul.jpg

Partner, Tax Controversy & Dispute Resolution

PricewaterhouseCoopers

Melbourne

+61 412861551

paul.mccartin@pwc.com

www.pwc.com.au/tax-controversy.html

Biography

Paul is one of Australia's leading tax controversy and dispute resolution advisors. He has over 20 years tax experience and spent over half his career as a senior ATO executive. Paul brings an unparalleled understanding of the ATO and its approach to audits. He uses this knowledge to resolve tax disputes on the best possible terms for his clients.

Recent matter highlights

Paul was the lead advisor to a global energy company involved in a cross border financing dispute. He led the collation of evidence, appeared at the GAAR Panel and led the negotiations. The potential adjustment was $1.5b and 50% penalties. Paul achieved negotiated settlement and no penalties were imposed.

Paul played a lead role in audit defence and settlement negotiations for an ASX listed company. The potential adjustment was $500m and was later resolved on favourable terms with no penalties.

Practice areas

Audit defence, Dispute resolution, Pre-litigation, MAPs/ADRs, Controversy management

Association memberships

The Tax Institute (Australia)

Chartered Accountants (Australia & New Zealand)

Academic qualifications

Masters of Taxation Law

pwc-110.jpg

Paul McNab

mcnab-paul.jpg

Tax Controversy Partner

PricewaterhouuseCoopers Australia

Sydney

+61 411366123

paul.mcnab@pwc.com

www.pwc.com.au/tax-controversy.html

Bar admissions: Admitted as a Solicitor and Barrister in the Supreme Court of New South Wales Entered in the High Court of Australia Register of Practitioners

Biography

More than thirty years of experience in Australian taxation law. Specialising in resolution of disputes with Federal and State Revenue authorities.

Management of audits and negotiations on behalf of taxpayers, conduct of tax litigation in the Administrative Appeals Tribunal, State and Federal Courts.

Recent matter highlights

  • Commissioner of Taxation v Financial Synergy Holdings Pty Ltd [2016] HCATrans 232 (7 October 2016

  • John Holland Group Pty Ltd v FCT [2015] FCAFC 82

  • Adams Bidco Pty Ltd v Chief Commissioner of State Revenue [2018] NSWSC 735

Practice areas

Audit defence, Pre-litigation, Litigation, Controversy management, International tax advisory

Sector specialisations

Automotive, Consumer goods and services, Financial services, Food and beverage, Gaming, Industrials, Media, Mining, Pharma and life sciences, Tech and telecoms

Association memberships

Chartered Tax Adviser, Australia

Academic qualifications

LL.B, QUT

LL.M (Hons), Sydney

Grad Dip Legal Practice Law, College of Law NSW

pwc-110.jpg

Eddy Moussa

moussa-eddy.jpg

Partner

PwC

Sydney

+61 282669156

eddy.moussa@pwc.com

pwc.com.au

Languages: English

Bar admissions: Solicitor of the Supreme Court, Federal Court and High Court of Australia

Biography

Eddy is a Tax Lawyer and Partner in the Tax Controversy Practice in Australia. He leads major complex audit defence for multinational and large private businesses. Areas of focus include anti avoidance, transfer pricing,WHT, financing and IP cases.

Recent matter highlights

  • Eddy has assisted clients under audit in a variety of industry sectors including Financial Services, infrastructure, FMCG, Technology and Real Estate.

  • He has also successfully resolved debt pricing, anti avoidance, transfer pricing cases involving material amounts of tax and penalties at stake.

  • Eddy has also published papers on evidence in tax disputes, anti avoidance, and taxation of intellectual property matters.

Practice areas

Audit defence, Dispute resolution, Pre-litigation, MAPs/ADRs, Controversy management

Association memberships

Member of the Law Society of NSW

Chairperson – State Council of the NSW Tax Institute of Australia

Academic qualifications

Bachelor of Business , Bachelor of Law – University of Technology Sydney

Masters of Taxation , University of Sydney

pwc-110.jpg

Simon Rooke

rooke-simon.jpg

Partner

PwC

Melbourne

+61 (3) 8603 4133

simon.rooke@pwc.com

www.pwc.com.au

Languages: English

Biography

Simon Rooke is a legal partner in PwC's Melbourne tax controversy practice. Simon specialises in working with clients to resolve complex and sometimes intense disputes with the Australian Taxation Office (ATO). Simon has over 20 years of taxation experience, including 12 years in international tax and M&A tax, which have led to several significant ATO investigations, up to and including litigation.

Recent matter highlights

Simon has extensive experience in assisting clients manage ATO disputes, including ATO risk reviews, ATO audits, settlement negotiations, alternative dispute resolution and litigation. Simon's approach is to take a respectful and educative approach to ATO investigations, while rigorously protecting a client's rights (both at law and under ATO practice and policy). Simon's experience has also ranged from navigating through the increasingly aggressive ATO approach to information gathering, to seeking private binding rulings on contentious tax matters, to assisting companies with 'ATO readiness' during initial public offerings, to litigation against the ATO when other avenues of dispute resolution are exhausted.

Practice areas

Restructuring, Transactions, M&A, Financial services, Corporate taxes, Audit defence, Dispute resolution, Litigation, Controversy management, Tax consulting, International tax advisory

Sector specialisations

Automotive, Consumer goods and services, Financial services, Pharma and life sciences

Association memberships

Law Council of Australia, Law Institute of Australia, Chartered Accountants Australia and New Zealand, Tax Institute

Academic qualifications

Bachelor of Laws (LLB); Bachelor of Commerce (B.Com), University of Tasmania, 1994

Practical Legal Training, College of Law, 2008

pwc-110.jpg

Judy Sullivan

sullivan-judy.jpg

Legal partner – tax controversy and national leader for tax litigation and alternative dispute resolution

PwC

Barangaroo, Sydney

+61 2 8266 0197

judy.sullivan@pwc.com

pwc.com/taxcontroversy

Judy Sullivan is a legal partner – tax controversy – and the national leader for tax litigation and alternative dispute resolution (ADR) at PwC.

Judy holds a BEc/LLB from the Australian National University and LLM from Sydney University. She is a member of the advisory panel to the Board of Taxation and a member of the Australian Taxation Office (ATO) dispute resolution working group. She is also a chartered tax adviser (The Taxation Institute) and on the High Court's roll of legal practitioners.

Judy is a leading tax lawyer and litigator in Australia. She joined PwC in 2013, and was formerly the tax partner leading the Sydney tax disputes practice at top tier law firm King & Wood Mallesons.

For over 25 years, Judy has guided multinationals, major corporates and high-net-worth individual clients through tax reviews, audits, negotiations and litigation across all areas of federal and state taxes. She has run or worked on seminal Australian tax cases in the Administrative Appeals Tribunal, Federal Court and High Court, as well as the NSW Supreme Court. She instructs and works with the leaders of Australia's tax bar.

With the ATO's shift to 'real time' engagement with taxpayers, Judy focuses on opportunities to work closely with the ATO and taxpayers to bring them together to achieve early engagement and resolution of disputes through ADR processes including settlement discussions, mediation and early neutral evaluation.

As cross-border transactions and corporate structures are under intense ATO scrutiny, (with significant additional ATO resources now applied to 'taskforces'), multinationals and major corporates must prepare to defend potential disputes in relation to their structures, transactions and pricing approaches.

Judy has extensive expertise across these topics and other important areas.

Judy also has a keen interest in pro bono matters, and has won the New South Wales Law Society Award for her pro bono work representing artists and establishing their practices as businesses for taxation purposes. She also leads PwC's charities and not-for-profits practice in Australia.

pwc-110.jpg

Angela Wood

wood-angela.jpg

Australian and ASPAC Leader – Tax Dispute Resolution & Controversy

KPMG Law

Melbourne

+61 400 988 723

angelawood@kpmg.com.au

home.kpmg.com/au/en/home/services/tax/advisory/dispute-resolution-controversy.html

Languages: English

Bar admissions: Admitted as a Barrister & Solicitor of the Supreme Court of Victoria, Federal Court of Australia and High Court of Australia

Biography

Angela is Australian & ASPAC Lead Partner for Tax Dispute Resolution & Controversy, representing large corporate taxpayers across the tax dispute continuum (transaction stage, reviews, audits, objections and litigation), drawing on extensive experience running significant litigation for the Commissioner of Taxation, to efficiently resolve disputes.

Recent matter highlights

Angela currently acts for taxpayers in several significant audit/litigation matters including a AUD$1 billion ATO audit of an infrastructure stapled structure (specific and general anti-avoidance provisions, deductibility of expenses between related parties and investors (domestic /offshore)), mineral royalty litigation for mining industry, reviews for transport and technology clients, large ATO audits of automotive and commodities clients (TP / anti-avoidance).

Practice areas

Audit defence, Dispute resolution, Pre-litigation, MAPs/ADRs, Litigation

Sector specialisations

Automotive, Banking, Consumer goods and services, Energy, Gaming, Industrials, Mining, Natural resources, Oil and gas, Pharma and life sciences, Tech and telecoms, Transport, Utilities

Association memberships

Chartered Tax Adviser – The Tax Institute of Australia

Member – Law Institute of Victoria

Law Council of Australia – Member of Victorian Tax Committee

University of Melbourne – Member of Tax Advisory Board (Melbourne Law School)

Academic qualifications

Bachelor of Laws & Bachelor of Arts, Monash University (1994)

kpmg-180.jpg

Howard Adams

EY

Rick Asquini

KPMG

David Bloom QC

New Chambers

Christopher Thomas Campbell

Deloitte

Michael Clough

King & Wood Mallesons

Fiona Craig

Deloitte

Gregory Davies QC

Victorian Bar

John de Wijn QC

Victorian Bar

Aldrin De Zilva

Greenwoods & Herbert Smith Freehills

David Drummond

KPMG

Sarah Dunn

KPMG

Bradley Edwards

Deloitte

James Fabijancic

Deloitte

Tony Frost

Greenwoods & Herbert Smith Freehills

Adam Gibbs

KPMG

Stewart Grieve

Johnson Winter & Slattery

Cameron Hanson

Herbert Smith Freehills

Dixon Hearder

Baker McKenzie

Andrew Hirst

Greenwoods & Herbert Smith Freehills

Ross Hocking

KPMG

Lyndon James

PwC

Greg Janes

Deloitte

Ashley King

TaxResolve

Chris Kinsella

Minter Ellison

Angelina Lagana

KPMG

Jonathon Leek

Deloitte

Nicholas Mavrakis

Clayton Utz

Paul McCartin

PwC

Geoff McClellan

Herbert Smith Freehills

Carmen McElwain

Minter Ellison

Paul McNab

PwC

Craig Milner

Allens

Alan Mitchell

Herbert Smith Freehills

Eddy Moussa

PwC

Peter Murray

Hall & Wilcox

Adrian O'Shannessy

Greenwoods & Herbert Smith Freehills

Ben Opie

KPMG

Trevor Pascall

Crowe Horwath Australia

Alex Patrick

KPMG

Hugh Paynter

Herbert Smith Freehills

Chris Peadon

New Chambers

Michael Perez

King & Wood Mallesons

Mark Poole

KPMG

Mark Richmond SC

Eleven Wentworth Chambers

Simon Rooke

PwC

John Salvaris

KPMG

Judy Sullivan

PwC

Brendan Sullivan SC

Tenth Floor Chambers

Reynah Tang

Johnson Winter & Slattery

Tom Thawley SC

New Chambers

Jerome Tse

King & Wood Mallesons

Jacques Van Rhyn

Deloitte

Chris Vittas

BDO

John Walker

Baker McKenzie

Paul Wenk

Herbert Smith Freehills

Angela Wood

KPMG

more across site & bottom lb ros

More from across our site

Companies in the UAE can prepare for a corporate tax regime in 2023, while the Trump Organization was found guilty of 17 counts of tax fraud.
The companies have criticised proposals for the gig economy, while the UK and EU VAT gaps have fallen in percentage terms, and ITR speaks to a European Commission adviser about its VAT reforms.
Corporations risk creating administrative obstacles if the pillar two rule is implemented too soon, sources say.
Important dates for the Women in Business Law Awards 2023
The Italian government published plans to levy capital gains tax on cryptocurrency transactions, while Brazil and the UK signed a new tax treaty.
Multinational companies fear the scrutiny of aggressive tax audits may be overstepping the mark on transfer pricing methodology.
Standardisation and outsourcing are two possible solutions amid increasing regulations and scrutiny on transfer pricing, say sources.
Inaugural awards announces winners
The UN’s decision to seek a leadership role in global tax policy could be a crucial turning point but won’t be the end of the OECD, say tax experts.
The UN may be set to assume a global role in tax policy that would rival the OECD, while automakers lobby the US to change its tax rules on Chinese materials.