About Ria Neilson
Ria Neilson is a trusted tax specialist who provides clear, strategic advice on complex Australian income tax issues for domestic and international clients. Known for her approachable style and deep understanding of client objectives, she combines meticulous attention to detail with practical, workable solutions.
Ria has particular expertise in the superannuation, private capital, infrastructure and resources sectors. While she has deep experience guiding clients through all stages of tax disputes, including pre‑litigation and Federal Court proceedings, her practice also spans transactional and advisory work. This includes advising on corporate transactions, cross-border tax issues and employment tax issues.
A contributor to the profession, Ria has published articles in the Asia Pacific Tax Bulletin and the International Transfer Pricing Journal. She has also presented at Tax Institute conferences and served as a guest lecturer at Melbourne Law School, sharing her insights with industry peers and emerging practitioners.
Ria's experience includes advising on:
Tax disputes and litigation
- Conducting litigation for a large superannuation fund concerning its entitlement to franking credits
- Advising infrastructure stapled groups on the resolution of multiple long‑standing disputes with the ATO, including on issues relating to thin capitalisation and transfer pricing
- Representing major infrastructure, resources, pharmaceutical and private capital clients in ATO disputes involving thin capitalisation, transfer pricing and valuation matters, including disputes concerning commodity pricing, intellectual property and inbound project financing.
Superannuation, funds and financial services
- Advising on successor fund transfers for large superannuation funds such as BT Super and Commonwealth Bank Group Super, including engagement with the ATO and Treasury
- Advising large superannuation funds on matters relating to franking credit entitlements in the context of complex hedging arrangements, including conducting litigation
- Advising retail, industry and public sector superannuation funds on member benefit and superannuation fund matters, including rectification of member contributions and annual reviews of product disclosure statements and member communications.
Other tax transactions and advisory
- Advising Newmont Corporation on the US$475m divestment of the Telfer Gold Copper Mine and Havieron Project to Greatland Gold
- Advising Vocus on the $3.5bn acquisition by Aware Super and Macquarie Infrastructure by way of scheme of arrangement
- Advising Unibail‑Rodamco on the $32bn business combination with Westfield Development Corporation
- Advising participants on renewable energy and infrastructure investments, including Renewable Energy Zone projects
- Advising various clients on the tax aspects of corporate transactions, cross-border tax structuring, employee share schemes, employment tax and debt capital markets programs.