29 October 2024
Taxation of multinationals – things to keep an eye on heading into the new yearRead moreDon SpirasonAnnemarie WilmoreKathryn Bertram
Annemarie is a taxation lawyer specialising in tax and revenue disputes, litigation and alternative dispute resolution. She helps taxpayers to protect against, manage and resolve their taxation disputes.
Annemarie’s expertise includes assisting a range of clients at all stages of the tax dispute continuum, from assessing tax risk in potential transactions, through to successfully defending filed positions in reviews, audits, objections and taxation litigation.
Annemarie has a strong understanding of tax policy and practice and advises on a broad range of issues including domestic and international Australian income tax, transfer pricing, superannuation guarantee charge, anti-avoidance provisions, payroll tax and state taxes.
Work highlights
Carriage of tax litigation (including test cases) against ATO and State/Territory Revenue Authorities
In matters such as Newmont Tanami Pty Ltd v Secretary, Northern Territory Revenue Office, Qantas v Chief Commissioner of State Revenue, Desalination Technology Pty Ltd v Commissioner of Taxation and Overseas Air Crew Basing Limited v Commissioner of Taxation.
Major global information technology company
Australian Taxation Office audit of the subsidiary’s Australian operations. Achieved successful settlement of dispute.
Major global resources company (coal)
General Anti Avoidance Rule regarding a debt financing transaction and preparation of a submission to the GAAR Panel.
Significant global entities in the information technology sector
Application of the Australian Multinational Anti- Avoidance Law and Diverted Profits Tax.
International wine and beverage group
Application of the Same Business Test spanning a period of 10 years to support the availability of carried forward losses in relation to the acquisition of the Australian group by an international private equity company.
International pharmaceutical group
Australian Taxation Office audit concerning the application of the General Anti Avoidance Rule.