Hugh Paynter is a partner in the Disputes practice of our associated law firm, Herbert Smith Freehills.
His full profile can be viewed on the Herbert Smith Freehills website.
Investigations & Disputes
The Full Federal Court decision in Chevron offers valuable lessons to multinational companies when it comes to managing the transfer pricing risks involved in intra-group financing.
Lessons from Chevron.pdf (274 kb)
The Full Federal Court has handed down its judgment in the Chevron case. Given that the hearing only began in late February, the omens were not good for the taxpayer – it doesn’t take long to write, ‘the taxpayer’s appeal is dismissed’.
Our comparison of the Australian and UK Diverted Profits Taxes reveals that in the majority of key areas, the Australian proposal is more onerous than the UK law.
Greenwoods & Herbert Smith Freehills, and Herbert Smith Freehills, have made a joint submission to the Senate Economics Legislation Committee on the proposed Diverted Profits Tax provisions of the Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017. The submission attaches earlier submissions we made on the Consultation Paper and exposure draft for the DPT.
DPT Senate Committee Submission March 2017.pdf (992 kb)
The Diverted Profits Tax legislation is now before Parliament. Its broad and draconian application should concern foreign and domestic multinationals alike.
Diverted Profits Tax.pdf (256 kb)