Allens

Charles Armitage

Partner
BEc LLB
Sydney | +61 2 9230 4756
Charles.Armitage@allens.com.au
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Charles has been providing corporate tax advice for more than 28 years covering all aspects of income tax law with particular emphasis on:

• debt capital markets transactions (including section 128F and tax treaty exemptions from interest withholding tax);
• equity capital markets transactions (including instalment warrants, etc);
• securitisation;
• mergers and acquisitions and capital management;
• infrastructure projects (including PPPs);
• project financing;
• chattel leasing and other asset financing transactions;
• funds management and the taxation treatment of trusts generally;
• private equity investments and divestments;
• pro-bono matters primarily involving the establishment of deductible gift recipients (DGRs); and
• tax audits and disputes.

Charles is recognised in Chambers Asia Pacific 2012 as a 'leading lawyer'. He is praised not only for his 'very strong technical skills' and adherence to a commercial rather than a narrowly legalistic line, but also for having 'retained a level head and negotiated a good outcome' in a particularly difficult transaction.

Some of the recent transactions in which Charles has been involved include:

• the groundbreaking A$2.8 billion multi-faceted Alinta debt restructure;
• the sale of the Westpac Office Trust to Mirvac;
• acting for MBIA/the receivers on the sale of the Lane Cove Tunnel;
• refinancing the ALE CMBS structure originally established as part of the float by Fosters of its pubs;
• new instalment warrant and capital protected loan offerings;
• bank and non-bank securitisations; and
• infrastructure projects ranging from toll roads, hospitals, schools and other such facilities to accommodation for defence forces personnel and for university students.

Charles has been involved in consultations with Government on various tax issues including:

• various tax changes which affect securitisation transactions (including the specific exemption from the thin capitalisation rules); and
• the repeal of section 51AD and Division 16D and the introduction of Division 250 and related infrastructure measures.