Andy Bubb
Clayton Utz
Special Counsel
Melbourne
You provided excellent service in resolving a very complex and lengthy dispute with the ATO, adding material value and agreeing the tax attributes of the investment going forward. We really appreciated your support.
– Client
Overview
As a tax lawyer, Andy focuses on resolving complex disputes, particularly for large multinationals. His expertise spans Federal and State-level tax matters, with a focus on contentious international tax and transfer pricing matters. He has wide experience in ATO dispute processes, having represented clients in various ATO processes and successfully negotiated settlements.
Notable Work
- Confidential client: advising one of the world's largest companies on the ATO's investigation of a treaty shopping issue.
- Infrastructure client: advising on a complex ATO audit of an Australian infrastructure asset owned by foreign pension and sovereign wealth funds, addressing GAAR and transfer pricing concerns.
- Entertainment client: advising an ASX-listed client on tax implications of disposing of its UK business.
- Gig economy client: advising on parallel investigations by state revenue offices and the ATO about whether the client's workforce were employees or contractors.
- ENR client: advised on a multifaceted ATO audit relating to the income tax and transfer pricing implications of two global restructures.
- Investment fund client: advising on an ATO audit of relating to whether capital gains tax (CGT) applied to a share sale, which depended on whether the shares were taxable Australian real property (TARP).
- Automotive client: advising on a multinational automotive client's restructure, including the general anti-avoidance rule (GAAR) and income tax issues.
- Private equity client: negotiating tax payment deferrals for a portfolio of companies owned by a private equity firm due to COVID-19-related cash flow issues.
- Sporting client: advising a national sporting code on a landmark transaction to maintain its income tax-exempt status.
- TTDB v Commissioner of Taxation: review by the Administrative Appeals Tribunal for an individual client about the personal income tax outcomes from various transactions (eg. loans) with related companies.
Insights
New test, new doubts on royalty withholding tax and diverted profits tax from Pepsi appeal
27 Jun 2024 | Article
Read Insights
Two taxpayer wins against the ATO in Federal Court GAAR cases – Minerva and Mylan
21 May 2024 | Article
Read Insights
Multinationals in Australia will feel Pepsi tax defeat for years
21 Dec 2023 | Article
Read Insights
IRS' and ATO's latest views on hot tax issues for multinationals
22 Mar 2023 | Article
Read Insights
Thin capitalisation and subsidiary tax residency – Draft legislation
17 Mar 2023 | Article
Read Insights
Urgent freezing orders a part of the ATO Deputy Commissioner's armoury against foreign entities – and courts will make them
3 Mar 2022 | Article
Read Insights
Transfer pricing financing disputes – the latest Australian instalment
23 Dec 2021 | Article
Read Insights
Meat, beer, and claims of legal professional privilege: the ATO's litigation BBQ and its implications for taxpayers
28 Oct 2021 | Article
Read Insights
The top five trends shaping disputes with the Australian Tax Office (and your tax risk) in 2021
16 Sep 2021 | Article
Read Insights
Find other people to support you
Find People