3 July 2024
Commissioner’s embedded royalty hunt divertedRead moreStewart GrieveAnnemarie WilmoreDon Spirason
Stewart acts for major corporate clients in relation to the conduct of Australian Taxation Office audits, reviews and enquiries and resolution processes to bring such audits, reviews or enquiries to a conclusion.
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, including the conduct of taxation reviews and audits; and the back-end of the review or dispute, which may include alternative dispute resolution processes or litigation.
Stewart is a Senior Fellow and Lecturer in the Law Masters programme at Melbourne University.
Work highlights
Microsoft Australian subsidiary
Relating to an ATO audit.
Anheuser-Busch InBev SA/NV
Various ATO reviews and audits.
SABMiller
Various ATO reviews and audits.
Foster’s Group Ltd
Various ATO reviews and audits.
Foster’s Group Ltd & various Foster’s Group companies
Proceedings in the Federal Court (Ashwick (Qld) No 127 Pty Ltd v C of T [2009] FCA 1388) and the Full Federal Court (FC of T v Ashwick (Qld) No 127 Pty Ltd [2011] FCAFC 49) concerning the deductibility of bad debts and interest outgoings totalling approximately $2.8 billion.
CUB Australia Holding Pty Ltd
Proceedings in the Federal Court (CUB Australia Holding Pty Ltd v C of T [2021] FCA 43) and the Full Federal Court (CUB Australia Holding Pty Ltd v C of T [2021] FCAFC 171) concerning the validity of notices issued under Division 353 of Schedule 1 to the Taxation Administration Act 1953.