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The comprehensive guide to the world's leading tax firms

The reputable tax group at Bell Gully is led by Willy Sussman and supported by strong partners in Niels Campbell and Mathew McKay. Clients commend the team for their "excellent service" and Sussman for his expertise in customs and excise tax. The trend ... [more]

The reputable tax group at Bell Gully is led by Willy Sussman and supported by strong partners in Niels Campbell and Mathew McKay. Clients commend the team for their "excellent service" and Sussman for his expertise in customs and excise tax. The trend of tax authorities becoming increasingly aggressive about challenging transactions on technical grounds has brought much more tax dispute work for the team over the past year. Campbell is considered by peers to be highly proficient in his understanding of capital markets and financial services industry.

McKay, Jarrod Walker, and Graham Murray advised subsidiaries of numerous Australian listed companies on a dispute with the IRD over the use of optional convertible notes (OCN) to fund investments. The trio is representing Alesco New Zealand in a dispute on this matter that will set a precedent for the treatment of OCNs. The team is challenging the IRD's assessment that the use of OCN does not constitute tax avoidance arrangements. The Court of Appeal hearing is set for October 2012. The case will have a significant effect on the application of New Zealand's anti avoidance law in addition to bringing greater clarity to operations in New Zealand following a trend in which there has been a conservative shift in favour of IRD.

Sussman assisted Smartfuel New Zealand in their national roll-out of the AA Smartfuel discount reward programme for consumers. Under the programme, individuals can redeem fuel discounts by purchasing goods and services from participating businesses. This deal required Sussman to come up with a tax solution that resolved difficulties with the associated GST.

In 2011, Ross Milne took over the leadership of Deloitte's tax practice. His predecessor Thomas Pippos, who remains in the team as chief executive, has been commended by a client as someone who performs particularly well in the "policy type area, dealing ... [more]

In 2011, Ross Milne took over the leadership of Deloitte's tax practice. His predecessor Thomas Pippos, who remains in the team as chief executive, has been commended by a client as someone who performs particularly well in the "policy type area, dealing with officials and lobbying for law changes".

The team provides taxation services across its general and specialists groups. They have seen a sharp decline in transactional work locally, but have been advising some of the most significant companies operating in New Zealand as well as successful owner-managed and family businesses.

Sources indicate that in addition to the range of services that the team offers, the team's expertise in indirect taxation matters is exceptional. Allan Bullot is highly regarded by his peers as a leader in this area. Teresa Farac is another notable individual for her work ranging from cross-border structuring, corporate tax and M&A. Farac has been described by a client as "quite innovative in thinking and practical".

The team continues to be active in the financial services industry and hired Campbell Rose from Russell McVeagh in June 2012. He is known for his deep knowledge of the financial services sector. The arrival of Rose will bolster the practice because of his relationships with many large New Zealand banks. Carl Church joined from the UK office and will be heavily involved in global financial services industry initiatives.

Peter Felstead represented Asahi in its acquisition of Independent Liquor. The transaction involved unwinding complex financing structures and introducing a new one. At the time of the transaction, the IRD had some concerns about the existing financing structure, so Felstead and the team advised Asahi on ensuring adequate warranties and indemnities were included within the agreement for sale and purchase and appropriate arrangements were agreed for the funding of any tax liability, penalties and interest ultimately payable.

Geoff Blaikie took over the leadership of Ernst & Young's tax practice in August 2011. The team has spent the last year strengthening their tax controversy practice, which is led by Kirsy Keating and is capable of assisting clients with all aspects of ... [more]

Geoff Blaikie took over the leadership of Ernst & Young's tax practice in August 2011. The team has spent the last year strengthening their tax controversy practice, which is led by Kirsy Keating and is capable of assisting clients with all aspects of their disputes with New Zealand and offshore tax authorities.

Ernst & Young have also been enhancing their transaction group in anticipation that activity in this area will pick up in the near future. Brad Wheeler joined Richard Williams from June 2012 to advise clients on specialist transaction services. Wheeler has a particular focus on the financial services industry. Matthew Hanley is a notable practitioner in the market for his knowledge of capital markets and the financial services industry.

The transfer pricing department is also held in good esteem inevitably, as a lot of the clients are foreign MNCs withpermanent establishments in New Zealand. Mark Loveday is highly respected by his peers as a transfer pricing adviser.

The tax authorities have identified transfer pricing audits to be a goldmine for revenue and the tax practice at KPMG has felt the effects of this focus as they have been busy helping their clients in tax audit defence and compliance work over the past ... [more]

The tax authorities have identified transfer pricing audits to be a goldmine for revenue and the tax practice at KPMG has felt the effects of this focus as they have been busy helping their clients in tax audit defence and compliance work over the past 12 months. The leader of the tax team is Paul Dunne who is chairman of the Institute of Chartered Accountants New Zealand tax committee. A client said: "The team has a very good relationship with the New Zealand Inland Revenue Department and they gave us a very pragmatic view of what is likely to be accepted by the IRD in any particular circumstance."

The team's global transfer pricing services leader, Kim Jarrett, has been working with clients on unilateral and bilateral advance pricing agreements (APA), including advice on the importance of pre-emptive planning and processes to ensure that sufficient and accurate documentation is maintained.

Greg Knowles and Rebecca Armour advised a large agriculture business on its vendor due diligence and restructuring of its operations. The work involved harmonising prolonged negotiations and differing objectives of the vendor shareholder group.

Knowles and Peter Scott were engaged for a tax dispute relating to the position of GST applicable to charities. The duo identified significant opportunities to obtain GST refunds through complex negotiations with the IRD. Ultimately, they were able to obtain a total of refund amounting to about $1.55 million (NZ$1.9 million).

The PwC tax team is led by Tony Gault. John Shewan, a tax practitioner, is chairman of the firm and is held in the highest regard by the market for his work in corporate tax, cross-border transactions and M&A. Clients often regard PwC's tax team as one ... [more]

The PwC tax team is led by Tony Gault. John Shewan, a tax practitioner, is chairman of the firm and is held in the highest regard by the market for his work in corporate tax, cross-border transactions and M&A. Clients often regard PwC's tax team as one of the best among the tax firms established in New Zealand. Peers similarly consider Eugen Trombitas to be a leading indirect tax practitioner.

The team spends their time helping clients with anything from day-to-day income tax and indirect tax matters to restructuring multimillion dollar property portfolios, international tax, transfer pricing and other specialist areas.

Russell McVeagh has earned a highly reputable status as a law firm with a tax practice. Though the team only has three partners and 11 other tax professionals, each partner is recognised in their own right as an accomplished and respected tax professional. ... [more]

Russell McVeagh has earned a highly reputable status as a law firm with a tax practice. Though the team only has three partners and 11 other tax professionals, each partner is recognised in their own right as an accomplished and respected tax professional. Fred Ward, Brendan Brown, and Shaun Connolly are practitioners that are able to advise on tax matters generally, though collectively they have an expertise in corporate tax and cross-border transactions paired with a thorough knowledge of the financial services industry.

The partners are "strong across the board. Brendan Brown is just a very talented and experienced tax lawyer," said one client. Clients commend Brown for being a "sensational transactional lawyer; I would recommend Brendan Brown and Fred Ward both for M&A type transactions, they excel in that area". Another noted "Russell McVeagh are people we use and value for tax law opinion, they have a good understanding of the New Zealand market and where we fit in the market…very responsive and good service".

In December 2011, Brown and Connolly advised Telecom in its $3.5 billion (NZ$4.3 billion) demerger, the first of its kind in New Zealand for a vertically integrated telecommunications company. As New Zealand's tax legislation does not contain general demerger relief provisions, the duo worked with the IRD to draft legislative amendments providing demerger tax relief specifically for this transaction, reflecting the matter's complexity and significance.

In addition to advising on the special legislation, Brown and Connolly's role included the establishment of debt programmes for the new entity created under the demerger, contractual arrangements between the demerged entities and liaising with offshore counsel to obtain rulings relating to the treatment of the demerger for shareholders in key offshore jurisdictions.

Chapman Tripp's tax practice is split between Auckland and Wellington. Veteran, Casey Plunket leads the Auckland tax team and David Patterson oversees the Wellington practice. The third partner, Graeme Olding is a tax litigation specialist who is held ... [more]

Chapman Tripp's tax practice is split between Auckland and Wellington. Veteran, Casey Plunket leads the Auckland tax team and David Patterson oversees the Wellington practice. The third partner, Graeme Olding is a tax litigation specialist who is held in high regard for his corporate tax knowledge. "We found them to be good to deal with, certainly the advice was clear and concise in terms of what they were looking for," said a client. Patterson is also known to have good credentials among clients for his knowledge in the oil and gas industries.

Plunket in particular is highly respected by all sources for his work on corporate tax, cross-border transactions and knowledge of the financial services industry. "Everyone in New Zealand knows [Plunket]. He's a pretty lateral thinker and covers most areas of tax, strong on legislative interpretation, but he has a very good practical sense as well," said a client. Another notes his capability in managing disputes with the IRD.

Plunket successfully acted for Direct Capital, ending a two year dispute with the IRD over the GST treatment of permanent establishment funds. The result is expected to have precedential effect on those in the same industry.

Patterson led a team of tax specialists to assist RESIMAC NZ Home Loans Ltd on their tax implications in a multifaceted transanction involving restructuring, redocumentation of warehouse funding arrangements and joint venture agreements. The tasks resulted from their clients acquiring 80% share of NZF Group's Home Loans Division securitisation business.

Andrew Ryan and John Peterson lead the tax practice at Minter Ellison Rudd Watts. Vivian Cheng acts as senior counsel to the team and there are four other professionals. Their capabilities cover indirect tax, corporate tax and tax disputes. A client ... [more]

Andrew Ryan and John Peterson lead the tax practice at Minter Ellison Rudd Watts. Vivian Cheng acts as senior counsel to the team and there are four other professionals. Their capabilities cover indirect tax, corporate tax and tax disputes. A client describes Ryan to be "very approachable and happy to help, often thinking innovatively". Peterson and Cheng are commended for their insight and application in financial arrangements and accrual work.

The team continues to be engaged for large transactions, including in the private-equity transactions industry. Over the past year, the courts' interpretation of legislation has become more conservative. A number of transactions that would not traditionally be considered avoidance have now come under scrutiny. Peterson and Sacha Oudyn are representing a client in a Court of Appeal case dealing with tax avoidance. The judgment will affirm or overturn the landmark decision in Penny v Hooper.

In late 2011, Peterson acted for ANZ, the bank, in matter concerning a finance lease of mining machinery to a significant New Zealand mining operation. The advice covered a number of complex legal issues in relation to the treatment of the lease for tax purposes, including under the financial arrangements and GST rules.

Barney Cumberland became a partner in January 2012, so there are now two tax partners in the Simpson Grierson tax team, the other being Stuart Hutchinson. The partners, supported by three other professionals, advise on a broad range of commercial transactions ... [more]

Barney Cumberland became a partner in January 2012, so there are now two tax partners in the Simpson Grierson tax team, the other being Stuart Hutchinson. The partners, supported by three other professionals, advise on a broad range of commercial transactions across all industries, as well as M&A, and capital raisings. Both partners are recognised in the market for their abilities in M&A and corporate tax work. Senior tax practitioner, Paul Windeatt is a specialist in the dispute and litigation area and Nicholas Bland plays a central role in providing tax advice to certain government departments.

Cumberland advised Coca-Cola Amatil (NZ) on a European medium term note (MTN) issue, with the instruments to be listed on the Singapore Debt Exchange. Few New Zealand corporations choose to use this form of funding, Cumberland was able to overcome challenging issues that arose about how clearing systems could manage New Zealand withholding tax.

Cumberland and Hutchinson teamed up to represent New Zealand Carbon Farming in significant forest acquisitions involving a GST transfer arrangement. The issue involved obtaining a clearance from IRD, dealing with novel issues including concerning the possibility of a future reversal of the transaction.

Maree Kempthorne heads the tax practice at Baker Tilly Staples Rodway, which has five partners and nine fee earners. Mike Rudd, a cross-border structuring specialist, has joined the firm from Ernst & Young.Roger Thompson obtained a binding ruling from ... [more]

Maree Kempthorne heads the tax practice at Baker Tilly Staples Rodway, which has five partners and nine fee earners. Mike Rudd, a cross-border structuring specialist, has joined the firm from Ernst & Young.

Roger Thompson obtained a binding ruling from the IRD for the DNZ Property Fund confirming the deductibility of a $32.4 million (NZ$40 million) payment for the termination of a property management agreement. Past applications of this nature tended to be rejected by the authorities but this ruling has set a precedent for similar applications. In the past, there was uncertainty as to whether a capital revenue split was considered capital expenditure or revenue ordinary expenditure. In such cases, the ruling was often unfavourable, however Thompson was successful in obtaining a ruling that deemed it to be revenue ordinary expenditure and thus deductible.

Grant Thornton's tax practice is led jointly by Colin DeFreyne and Murray Brewer. The firm is capable in all areas of tax advisory work, with an emphasis on transactional tax and M&A, and has a strong corporate finance team. DeFreyne frequently deals ... [more]

Grant Thornton's tax practice is led jointly by Colin DeFreyne and Murray Brewer. The firm is capable in all areas of tax advisory work, with an emphasis on transactional tax and M&A, and has a strong corporate finance team. DeFreyne frequently deals with international tax and transactional matters and Brewer often looks after high net worth individuals and expatriate tax issues. Greg Thompson and Mike Chadwick both possess an expertise in transfer pricing.

DeFreyne is a notable figure among clients who note "he was perfect and understood tax due diligence in the corporate transaction and structuring side for tax efficiency". Another added: "he's got the knowledge, explains it well and he's got very nice mannerisms". In the past 12 months, the team has been busy with transactional matters, in particular inbound M&A work, general tax and due diligence matters.