Taxation

As Australia continues to grow as a regional financial services hub, an intimate knowledge of taxation law and the associated regulation is more important than ever.

Taxation is a highly technical area that is constantly subject to change and requires an ongoing monitoring and analysis of the impact of Federal and State taxation.

Clients appreciate our depth of knowledge of the technical issues which is delivered with practical advice on how taxation and finance options work in practice, how they interact with other areas of the law and how new legislation and compliance will impact specific areas of a business.

We are trusted advisers to public and private companies, foreign corporations and banks on the tax implications of mergers and acquisitions, disposals, corporate restructures, property and infrastructure projects, financing and leasing arrangements, tax consolidation and the establishment on new businesses.

We also provide practical tax advice to property developer clients on income tax, GST and stamp duty and on the taxation aspects of project finance opportunities in the public sector.

Our tax expertise includes:

• stamp duty
• corporate restructures
• project refinancing 
• property and Infrastructure Projects
• tax consolidations
• financing and Leasing arrangements
• tax rulings
• GST
• state taxes
• tax advice on the establishment of new businesses.

Babcock and Brown International Pty Ltd

We advised a group of syndicated banks, which included domestic and foreign entities, on the restructure of a $3 billion debt facility for Babcock and Brown International Pty Ltd. Our advice included issues associated with the application of sections 45B and 45C of the Income Tax Assessment Act 1936, the debt/equity rules, and the availability of the interest withholding tax exemption to interest payments made.

ABC Learning Centres

We advised the receivers of ABC Learning Centres in relation to the sale of ABC's offshore businesses. This included a detailed capital gains tax review of the various aspects of the sale transaction, the implications of the repatriation of funds from offshore investments for the head company of a tax consolidated group and the tax treatment of the disposal of partnership interests.

Eureka Funds Management

We advised Eureka Funds Management on the establishment of all its core funds, including Eureka Property Funds No 1, Alternative Investment (Real Estate) Private Syndicate Trust, Alternative Investment (Hotel and New Zealand Private Syndicate) and core funds 3A and 3B (property funds). Collectively these funds had assets of more than $1.25 billion.

Man Investments Australia

Advisers to the issuers of the OM-IP series of funds sponsored by Man Investments Australia Limited (MIA) which have raised over $1.9 billion in Australia and New Zealand.

Quentin Ayres

Worked on the tax aspects of various complex investment structures for Quentin Ayers Pty Ltd, to enable Australian superannuation funds to invest in liquid and semi-liquid assets in various offshore jurisdictions. This included advice on the taxation of trusts and various distributions, treatment of foreign income and foreign income tax offsets, consideration of foreign investment fund and controlled foreign company rules.