Stewart Grieve Partner

Stewart is a taxation lawyer specialising in tax audits and disputes. He acts for clients in relation to resolution processes that will expedite the conclusion of audits or enquiries.

Stewart’s taxation disputes practice is “end-to-end”, which means that he advises clients on all aspects of the front-end of the dispute. This includes the conduct of taxation risk reviews and audits, as well as all aspects of the back-end of the dispute which may involve alternative dispute resolution processes or litigation.

He also advises clients not already in a dispute with a revenue authority on how to avoid such disputes, and assists those already in a taxation dispute with advice on how the dispute can be resolved as expeditiously and advantageously to the client as possible.

Stewart acts for major corporate clients in the conduct of ATO audits and enquiries, and has for a number of years been listed as one of Australia’s Best Taxation Lawyers and in the International Tax Review Tax Disputes Leaders Guide.


Taxation Audits & Enquiries

Major global information technology group

Acting for the Australian subsidiary of a major global information technology group in relation to an Australian Taxation Office audit of the subsidiary’s Australian operations.

Major global manufacturing group

Acting for an Australian subsidiary of a major global manufacturing group in relation to an Australian Taxation Office Large Business Audit.

Foster’s Group Ltd

From 1993 to present, advised Foster’s and its subsidiaries in relation to various Australian Taxation Office risk reviews and audits.

Privately owned company

From 2012 to 2014, acted for a privately owned company in relation to an Australian Taxation Office audit.

Taxation Litigation

Foster’s Group Ltd & various Foster’s Group companies

From 2007 to 2011, acted for a number of Foster’s Group companies in Federal Court and Full Federal Court proceedings concerning the deductibility of bad debts and interest outgoings totalling approximately $2.8 billion.

Law Institute of Victoria

In 2014, acted for the Law Institute of Victoria in relation to Supreme Court proceedings concerning the LIV’s payroll tax status.


Career & qualifications


  • Master of Laws, Monash University
  • Bachelor of Commerce, University of Queensland
  • Senior Fellow and Lecturer, Melbourne University Law Masters Programme


  • Tax Institute of Australia
  • Law Council of Australia Taxation Subcommittee
  • Tax Advisory Board member for the Melbourne University Law Masters Programme

International experience

  • Taxation Director of Foster’s Group Limited’s Taxation Group with responsibility for the taxation affairs, Asia/Pacific, the US and EMEA (2009-2010)
  • Assisted Foster’s with managing two tax litigation matters, India

Insights Read more insight

Insights from the Federal Court’s latest decision on LPP

We recently commented upon a heavily redacted version of Moshinsky J’s judgment in Commissioner of Taxation v PricewaterhouseCoopers [2022] FCA 278 (PwC case).

The ATO ramps up its recovery of existing and anticipated tax debts

Central to the Australian taxation system is the concept of self-assessment. Voluntary compliance for the payment of tax related liabilities is strong with Australian Tax Office (ATO) data...

Commissioner of Taxation’s access powers

The Commissioner of Taxation has broad powers to obtain information and documents for the purposes of his administration of Australia’s tax laws.



External publications

  • Author of the Australian chapter of the Thomson Reuters publication, Tax Litigation
  • Author of the Australian chapter of the Thomson Reuters publication, Transfer Pricing & Tax Avoidance


  • Law Council, Taxation Subcommittee submission on the Australian GAAR


  • The Australian GAAR, How Tax Officials can Establish Trust with Taxpayers, Asian Tax Executives Forum 2013