Overview
Tax law influences capital allocation, transaction design and long-term wealth preservation. Legislative change, heightened revenue authority scrutiny and expanding anti-avoidance regimes mean tax risk is now a core strategic consideration for boards, investors and founders.
Thomsons advises corporate groups, institutional investors, trustees and private clients on structuring and managing tax exposure in environments where commercial objectives, regulatory interpretation and fiscal efficiency intersect. We work alongside transaction, finance and governance teams to ensure tax settings are integrated into commercial decisions, not addressed after them.
Our focus is commercial, practical and defensible execution: structuring arrangements that withstand regulatory challenge, align with evolving policy settings and protect enterprise and personal value across the lifecycle of ownership and investment.
Areas of expertise
Our experience
Commissioner of Taxation – Administrative Review Tribunal and Federal Court proceedings
Acted for the Commissioner of Taxation in Administrative Review Tribunal and Federal Court proceedings involving complex tax law questions, cross-border evidentiary issues and disputes with participants in Singapore and China. Several assignments are expected to establish legal precedent. The evidentiary record in individual cases exceeds tens of thousands of pages.
Alloy Steel Australia (Int) Pty Ltd – Sale of business
Advised Alloy Steel Australia on the tax and structuring aspects of the A$209 million sale of its remaining interest in a family-owned business to Lincoln Electric Holdings, Inc. (Nasdaq, market cap US$15 billion), a cross-border transaction involving Australian and US tax considerations.
Advised Iron Mine Contracting – Tax aspects of acquisition
Advised Iron Mine Contracting, a leading Western Australian mining and construction services contractor, on the tax aspects of its approximately A$115 million acquisition by NYSE and TSX-listed North American Construction Group, including drafting and negotiating tax indemnity and warranty provisions and addressing complex tax consolidation issues.
Indivior Group (via Eversheds Sutherland) – Corporate restructure
Advised the Indivior Group (via Eversheds Sutherland) on Australian tax issues arising from a multi-jurisdictional corporate restructure valued at A$100 million, with particular focus on cross-border elements affected by recent changes to Australian tax law.
Anacacia Capital – Continuation fund establishment
Advised Anacacia Capital on the establishment of one of Australia's first private equity continuation funds, a cross-border A$250 million transaction involving multi-jurisdictional funds management, M&A considerations and FIRB approval requirements, with a cornerstone investor from Japan.
Sydney Metro – Complex GST issues
Advised Sydney Metro on complex GST issues arising under a major project development agreement, including the timing of GST attribution, non-monetary consideration, invoicing obligations and the treatment of a Value Share Payment under the Victoria Cross Integrated Station Development Agreement. The overall transaction value was A$227.7 million.
Wildstone Capital – Tax structuring on Australian transactions
Advised Wildstone Capital on the tax structuring of its first Australian transactions, the acquisition of multiple outdoor advertising sites in Victoria. Identified and resolved material stamp duty exposure through targeted structuring and submissions to the State Revenue Office Victoria, achieving a confirmed duty saving, and separately secured a 50% stamp duty concession on a high-value site acquisition under Victoria's regional commercial and industrial property concession.
South Australian Housing Trust – Restructuring and partnership tax issues
Advised the South Australian Housing Trust, the primary provider of public and community housing in South Australia, on complex GST issues arising from the restructuring of its development activities and partnerships with community housing providers.