Angela Wood

Clayton Utz
Partner Melbourne

Angela Wood at Clayton Utz is “highly skilled at managing tax disputes”, according to sources who commend her work on behalf of SME, HNWI and large-scale corporations

– Who’s Who Legal

Overview

A leading tax dispute resolution and litigation lawyer, with an exceptional track record of success over 25 years’ dedicated practice in the field. Focused on proactive, efficient and early resolution of disputes, advising multinational and large domestic corporates, private groups and high net wealth individuals. Advises at all stages of tax disputes, from early regulator engagement at transaction, through reviews, audits, independent review, GAAR panel and objections. Brings deep tax litigation experience, having run significant Federal, State and High Court matters for both the Commissioner of Tax and taxpayers. Lauded for her strategic counsel, strong ATO connections, and the ability to balance robust taxpayer representation with productive regulatory relationships, consistently delivering optimal outcomes.

Angela is the National Practice Group Leader of the Tax team.

Notable Work
  • Infrastructure Client: advised on a complex ATO audit related to stapled structures, addressing GAAR and transfer pricing.
  • Multinational Resources Client: assisted with ATO audit of internal restructures, involving GAAR, MAAL, and transfer pricing.
  • Confidential Client: provision of strategic dispute management advice in ATO audit regarding transfer pricing and treaty shopping
  • Technology Company: successfully resolved disputes related to the application of the Multinational Anti-Avoidance Law
  • Multinational Commodities Business: resolved significant ATO audit issues, including Part IVA and transfer pricing matters.
  • Foreign Private Equity Fund: successfully navigated early engagement with the ATO to avoid a dispute regarding divestment in Australia.
  • Entertainment Client: provided tax advice for an entertainment client's offshore operations wind-up, addressing GAAR and CGT participation exemption.
  • Automotive Client: advised on the tax implications of a multinational automotive client's restructure, addressing GAAR and income tax issues.
  • Resources Client: advised on the FIRB process for a client's restructure and refinancing, focusing on GAAR issues.
  • Commissioner of Taxation: acted in a significant mediation for a landmark related party financing transfer pricing dispute.
Insights
New test, new doubts on royalty withholding tax and diverted profits tax from Pepsi appeal
27 Jun 2024 | Article
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Two taxpayer wins against the ATO in Federal Court GAAR cases – Minerva and Mylan
21 May 2024 | Article
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Australian Budget 2024 walks a fine line, and steps over details for multinationals and foreign investors
15 May 2024 | Article
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Tax Disputes Podcast with Slaughter and May
8 May 2024 | Audio
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Multinationals in Australia will feel Pepsi tax defeat for years
21 Dec 2023 | Article
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Top 5 trends in 2023 ATO disputes: the musical
18 Dec 2023 | Article
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Media release: Clayton Utz named Australia's Tax Disputes Firm of the Year at 2023 ITR APAC Tax Awards
6 Oct 2023 | Article
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Thinking about investing in Australia? Here's how the Federal Budget 2023-24 affects you
11 May 2023 | Article
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Fewer revenue measures in Budget 2023-24 signal a holding pattern with more compliance – for now
10 May 2023 | Article
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IRS' and ATO's latest views on hot tax issues for multinationals
22 Mar 2023 | Article
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Media Release: Clayton Utz to co-host Australian and US tax regulators in conversation, with dispute management on the agenda
1 Mar 2023 | Media Release
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Budget 2022-23: multinationals, franking credits to boost tax take, and force strategy rethink
26 Oct 2022 | Article
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Five ways that tax litigation is different
1 Jun 2022 | Article
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Morrison Government's middle of the road 2022 election year Budget offers some (but not much) relief for Australian businesses
30 Mar 2022 | Article
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Urgent freezing orders a part of the ATO Deputy Commissioner's armoury against foreign entities – and courts will make them
3 Mar 2022 | Article
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Transfer pricing financing disputes – the latest Australian instalment
23 Dec 2021 | Article
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Taxpayers + transfer pricing = more ATO attention
25 Nov 2021 | Article
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Meat, beer, and claims of legal professional privilege: the ATO's litigation BBQ and its implications for taxpayers
28 Oct 2021 | Article
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ATO on high alert for overclaimed fuel tax credits
17 Sep 2021 | Article
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The top five trends shaping disputes with the Australian Tax Office (and your tax risk) in 2021
16 Sep 2021 | Article
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