About Toby Knight
Toby is a corporate and international tax specialist with expertise in dispute resolution, ATO audits, transfer pricing, anti-avoidance rules (Part IVA, DPT) and tax litigation.
He advises on capital gains tax, restructures, tax consolidation, foreign exchange, intangible migrations, hybrid instruments and international transfer pricing. Toby is widely consulted on the Commissioner’s access powers and anti-avoidance provisions.
His clients include multinationals, ASX-listed companies and high-net-worth families. He has extensive experience in ATO mediations, settlements, Mutual Agreement Procedures and tax treaty issues.
Toby is a member of the Tax Committee of the Law Council of Australia and a Chartered Tax Adviser of the Tax Institute of Australia and is ranked as a Leading Tax Lawyer in both Chambers Asia Pacific 2025 and Legal 500 Asia Pacific 2025.
He acts on transfer pricing and anti-avoidance disputes involving:
- Intra-group financing, including issues such as the imputation of parental guarantees and guarantee fees and expert evidence on credit ratings, interest rates and the quantum of guarantee fees
- Redeemable preference shares, including the application of the debt/equity rules, the thin capitalisation provisions, Subdivision 815-B and Part IVA
- Distribution arrangements in the pharmaceutical and automotive industries
- Intellectual property licensing and assignment transactions, including DPT and Royalty Withholding Tax issues
- Commodity sales in the mining and oil and gas sectors.