Philip Bisset
Clayton Utz
Consultant
Brisbane, Perth
Overview
Philip is a key specialist tax adviser to energy and resources companies, combining tax advice in all facets of revenue law (including taxation, stamp duty, GST and Petroleum Resource Rent Tax) with acting for clients in tax disputes.
Previously a partner in "big four" accounting firm and in-house with Exxon and Rio Tinto, Philip has a strong practical knowledge of major facilities (such as oil platforms and gas plants). He works closely with corporate tax teams to structure the tax aspects of inbound and outbound investments, and devise tax dispute resolutions that are robust and commercial. He has a specialist knowledge of the Petroleum Resource Rent Tax and is one of few tax lawyers to have worked with clients continuously on the impact of the PRRT since its introduction in 1990.
Notable Work
- Confidential resources client: advising on the income tax, duty and GST aspects of settlement of a dispute over ownership of significant resources project.
- Large US/Canadian miners: acting in a confidential matter before the Federal Court on capital gains consequences the sale of a minority holding in a large Australian mining holding. This ongoing case involves complex valuation and treaty issues.
- Various non-resident investors: acting as instructing solicitor in the Federal Court at first instance and on appeal to the Full Court and High Court for landmark cases involving the interpretation of international tax treaties and the taxation of the disposal of shares by a non-resident in Australian companies.
- Office of State Revenue: advised on a number of matters relating to payroll tax disputes regarding the grouping of taxpayer entities for payroll tax purposes. There were excellent results in the matters.
- Resource Capital Funds III, IV and V LP v Commissioner of Taxation: acting as instructing solicitor in the Federal Court at first instance and on appeal to the Full Court and High Court for landmark cases involving the interpretation of international tax treaties and the taxation of the disposal of shares by a non-resident in a mining company.
- Confidential resources client: assisted with negotiating and structuring government assistance for a major Australian refinery development.
Insights
Australian Budget 2024 walks a fine line, and steps over details for multinationals and foreign investors
15 May 2024 | Article
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Further changes to the Petroleum Resource Rent Tax Assessment Act on the way
21 Mar 2024 | 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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Budget 2022-23: multinationals, franking credits to boost tax take, and force strategy rethink
26 Oct 2022 | Article
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Broadening the H(Aurizon): a shift toward declaratory relief for taxpayers?
24 Jun 2022 | Article
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'Till debt do us part’: when are you liable for your business partner's tax bill?
24 Jun 2022 | Article
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Privilege and multidisciplinary partnerships: Federal Court hands down critical privilege guidance
14 Apr 2022 | Article
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When can we challenge ATO conduct? Court finds Tax Office's actions "oppressive"
14 Apr 2022 | Article
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Federal Court confirms ATO's broad powers (and duty) to use documents in its possession, even Court documents
31 Mar 2022 | Article
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Review your engagements with multidisciplinary partnerships involving non-lawyer tax advisers to ensure privilege will not be lost
31 Mar 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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Statutory interpretation and tax law: examples from Shell's Court win in deducting its exploration assets
3 Mar 2022 | Article
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Australia's Federal Budget 2020: solid and unsurprising stimulus measures, and some opportunities for business
7 Oct 2020 | Article
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Hacked? Don't expect legal professional privilege to stop others using your documents, says High Court
14 Aug 2019 | Article
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Federal Budget 2019: incremental, not dramatic, changes for corporate Australia and multinationals
3 Apr 2019 | Article
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Documents you give to other parties in litigation can end up with the ATO
29 Mar 2018 | Article
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Foreign investors in Australian resources projects receive important income tax guidance from Federal Court
12 Feb 2018 | Article
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1 July 2017 start for significant changes to the Foreign Resident CGT Withholding Tax regime - are you ready?
23 Jun 2017 | Article
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Federal Budget 2017: banks, property investors and multinationals in the spotlight
10 May 2017 | Article
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