Stewart Grieve Partner

Stewart is a taxation lawyer with over 30 years’ experience specialising in taxation audits and disputes.

Stewart acts for major corporate clients in relation to the conduct of Australian Taxation Office audits and enquiries and resolution processes to bring such audits 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 risk reviews and audits; and
  • the back-end of the dispute, which may include alternative dispute resolution processes or litigation.

Stewart lectures in the Master of Laws program at Melbourne University.


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

Guardian: the Full Federal Court confirms Part IVA applies on round two of trust distributions

The Commissioner of Taxation (Commissioner) has been actively pursuing the application of the anti-avoidance provisions to trust structures and trust distributions. In the most recent decision, the...

Court finds arrangements that include a trustee's income distribution decisions are Part IVA schemes

A single judge of the Federal Court has upheld a decision of the Commissioner of Taxation (Commissioner) to apply the general anti-avoidance rule, Part IVA, to arrangements that include the income...

Updated ATO approach to accessing records and information

On 22 June 2022, the Australian Taxation Office (ATO) published its finalised Protocol for claiming legal professional privilege (the Protocol). The Protocol has been developed to assist taxpayers...



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