In this section

The tax environment in Australia presents challenges for businesses operating or investing in this market.

Changing regulations concerning transaction structures for foreign investors, intense political scrutiny of the treatment of the tax information, and tax and revenue authority use of enhanced profiling techniques and broad information-gathering powers to identify risk areas, and scrutinise the Australian and state tax and duty implications of business dealings, are some of the more significant tax issues faced by businesses active in Australia.

How we can help

Our tax specialists provide precise, commercially informed advice on all areas of direct and indirect taxation, covering income tax, capital gains tax, GST, stamp duty and land tax.

Well versed in the issues on the radar of the Australian Taxation Office (the ATO) – with which we have a productive working relationship built up over many years – we guide businesses to proactively manage and respond to changes in tax laws, and assist with the tax optimisation of transactions, and to navigate scrutiny should it arise.

Optimising the tax outcomes on transactions

Familiar with a diverse range of asset classes and investment structures, our tax specialists advise on structuring and documentation to ensure tax outcomes align with commercial objectives on transactions. We advise across all types of transactions and circumstances, including restructuring, M&A, capital management, investments and divestments – renowned as a ‘safe pair of hands’ by clients, who trust us to guide them through all of their major transactions and circumstances.

Our indirect tax specialists provide advice on all stages of transactions, to ensure the most efficient outcomes from the perspective of stamp duty and GST costs – covering the breadth of issues and risks that may impact your business.

It is the case more often than not that our tax specialists work together with our corporate M&A and investment fund specialists to provide holistic and integrated support, ensuring optimal tax outcomes on significant transactions. At the cutting edge of tax law developments in Australia, our specialists are currently acting on some of the country’s largest transactions, and guiding influential participants through upstream and downstream structuring issues. Our specialists are well placed to help you to proactively protect your business and investments, and navigate regulatory scrutiny should it arise.

Navigating interactions with the ATO and revenue authorities

Businesses have different risk profiles, which influences how they choose to navigate interactions with tax regulators and authorities. Allens' tax experts offer a commercial and solutions-based approach to navigating these interactions, informed by deep experience, and a productive relationship with the ATO and other revenue authorities – which enables us to influence and challenge analysis on contentious issues.

Allens' tax controversy specialists have an outstanding reputation and track record in dispute resolution, including litigation and audit management (see Tax Disputes).


Merger of Sunsuper and QSuper to form Australian Retirement Trust

Advising on all direct and indirect tax (including stamp duty) aspects of Sunsuper's merger with QSuper to form Australian Retirement Trust, Australia's second-largest superannuation fund with over 2 million members and more than $200 billion in funds under management.


Advising on the tax aspects of the $10.2 billion acquisition by a Brookfield-led consortium of 100 per cent of AusNet shares via a scheme of arrangement.

IFM Investors

Advising on tax aspects of the establishment in 2022 of a Net Zero Fund for global renewable infrastructure projects.


Advising on the tax aspects of its response to a $3.5 billion take-private proposal by way of scheme of arrangement by Aware Super and Macquarie Infrastructure and Real Assets.


Advising on all direct and indirect tax considerations as part of the acquisitions of Westpac's Angle Finance motor vehicle dealer finance and novated leasing business, and Strategic Alliances equipment finance business – two large-scale securitisations totalling more than $1.6 billion.

ALE Property

Advising on the $1.7 billion takeover by scheme of arrangement by Charter Hall and Hostplus.


Advising on all tax aspects of the acquisition of a 70 per cent stake in Australia Tower Network for approximately $1.9 billion.

Offshore headquartered family office

Advising on estate planning and compliance for Australian-resident ultra-high net worth individuals and their related entities, including acting on multiple Top 500 Private Groups Tax Performance Program reviews by the ATO within the same family.

Magellan Financial Group Limited

Advising on a $16 billion trust restructure to combine three Magellan managed global equities funds into a single trust, the Magellan Global Fund – and investment in a new full service investment banking start-up.

Construcciones y Auxiliar de Ferrocarriles, S.A.

Advising on tax considerations in relation to its investment in the NSW Regional Rail PPP.

BGH Capital

Advising on the acquisition of Healius's medical centres and dental clinics businesses, and its separation from Healius's day hospitals and IVF clinics business.

Sale of ANZ's wealth management business to Zurich for $2.85 billion

Advised on the sale of ANZ's wealth management business to Zurich for $2.85 billion. This involved advising on the income tax and capital gains tax issues.