Strategy, Technology
& Tax — Built to Run.

Engagement Overview

Provided Australian tax advice and led the coordination of multi-jurisdictional corporate law advice for a major US-headquartered multinational with a substantial global operating structure. The core work centred on advising on the tax implications of repatriating profits accumulated across Australian and foreign subsidiaries to the US parent — requiring a command of Australian tax law, an understanding of how the broader corporate structure interacted across jurisdictions, and the ability to orchestrate specialist advice from across a global professional services network.

Coordination & Delivery

Beyond the Australian tax advice, the engagement required coordinating the provision of corporate law advice across multiple jurisdictions — identifying the right advisors, managing cross-border handoffs, and synthesising outputs into a coherent strategy for the client. This is the architecture dimension of the work: understanding the full structure, knowing what questions to ask in each jurisdiction, and ensuring the advice held together as a whole.

Key Deliverables

• Australian tax advice on profit repatriation — analysis of distribution pathways from Australian entities to US parent
• Cross-border dividend and distribution analysis across multiple tax treaty and holding structures
• Coordination of corporate law advice across multiple jurisdictions within the group's global structure
• Synthesis of multi-jurisdiction outputs into a coherent repatriation strategy

Engagement Overview

Delivered full start-to-finish global tax effect reporting for an ASX 100 mining and resources group — one of Australia's largest listed companies in the sector. The engagement covered the entire consolidated group, requiring identification and calculation of temporary differences across every entity in the structure, current and deferred tax computations, effective tax rate reconciliation, and preparation of all related note disclosures for the statutory financial statements. The scale and complexity of the group's multi-division, multi-entity structure — spanning contract mining services, iron ore, lithium joint ventures, and energy operations — made this a substantial and technically demanding piece of work.

Structural Complexity

The group operates through a large consolidated structure with numerous wholly-owned subsidiaries across its four core divisions, alongside equity-accounted joint venture interests in its lithium operations. Each layer of the structure carries distinct tax considerations: the tax consolidation group for wholly-owned entities, separate deferred tax treatment for JV interests, and the interplay between temporary differences arising from the group's significant asset base, capital expenditure programs, and commodity-driven revenue cycles. Tax effect reporting at this scale demands both technical precision and a command of how the group's business model drives the numbers.

Key Deliverables

• Full identification and calculation of temporary differences across the consolidated group
• Current tax and deferred tax asset / liability computations for all entities
• Effective tax rate (ETR) reconciliation for statutory reporting
• Tax note disclosures prepared for ASX financial statement lodgement
• Tax consolidation analysis across wholly-owned group entities
• Separate deferred tax treatment for equity-accounted joint venture interests

Engagement Overview

Provided Australian tax advice on a AUD $143 million corporate restructure into a 50:50 joint venture structure between an ASX-listed Australian resources group and an international investor. The restructure involved establishing a new JV entity to hold and develop the underlying resource asset, requiring careful consideration of the Australian tax implications of the reorganisation — including the treatment of the asset transfer, the incoming foreign investment, and the ongoing tax position of the joint venture structure. As with the coordination dimension of the work, advice from across a broader advisory team was managed to ensure the tax and structural elements aligned.

Key Deliverables

• Australian tax advice on the corporate restructure and transfer of the resource asset into the JV structure
• Tax analysis of the inbound foreign investment and cross-border structuring considerations
• Advice on the ongoing Australian tax position of the 50:50 joint venture entity
• Coordination of the broader advisory team to ensure tax and structural elements were aligned across the transaction

Engagement Overview

Managed the personal tax affairs and corporate structuring for a world champion Australian professional athlete during a significant contract renegotiation with a global sports promotion organisation. The engagement went beyond compliance — a new corporate structure was established as part of the renegotiation, and direct correspondence was conducted with the promotion's own tax team on the financial details and revisions of the contract. This required navigating the intersection of personal tax, entity structuring, and commercial negotiation in a high-profile, time-sensitive context.

Key Deliverables

• Personal tax compliance and advisory for a high-profile professional athlete
• New corporate structure designed and established as part of the contract renegotiation
• Direct correspondence with the counterparty organisation's tax team on contract financial terms and revisions
• Tax advice on the structuring of income flows through the new entity