Mallesons is a new breed of global law firm. With 29 international offices located in the world's major financial centres and growth capitals, we are ideally positioned to support our clients in all aspects of their multinational tax strategy.
Our full-service tax practice offers strategic and integrated tax advice on all commercial tax matters, applying an international lens to such advice where applicable. We have experts across the full spectrum of Australia’s international tax regime, including in relation to various inbound and outbound investment structures. We are also at the forefront of legislative and policy developments from an international tax perspective.
We are leaders in international tax advisory services and support our multinational clients with mergers and acquisitions transactions, capital returns or reorganisations, financial transactions and global growth. We can undertake tax due diligence, obtain rulings and other approvals from the Australian Taxation Office and State/Territory tax authorities in connection with such transactions, and guide our clients through new investor and other early engagement services offered by our revenue authorities. We prepare, review and negotiate the terms of the tax-related documentation required to give effect to such transactions.
International tax expertise where you need it
We have a leading transfer pricing practice advising multinationals on transfer pricing risks for new transactions and structures, using our experience gained in running the vast majority of leading Australian transfer pricing cases. Our particular experience and knowledge of common structures that are acceptable in the Asian market means that we’re ready to jump when any of our global clients push ‘go’ on their Asian investment strategies.
Leading tax experts in global information reporting
We are foremost legal experts on Automatic Exchange of Information (AEOI) in the Australian market. We have advised a diverse range of ‘foreign financial institutions’ (FFIs) and industry on their AEOI compliance since the inception of the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) and through key regulatory changes since.
We are particularly sought after for our legal advice on the application FATCA and CRS rules which are constantly evolving. We prepare best practice governance controls to underpin AEOI frameworks, identify systems gaps and ensure correct reporting so that all reportable accounts are identified and overreporting is avoided.
How we can help you
Our preeminent international tax advisers can assist with:
- Inbound and outbound structuring and advice, including liaising with our global network where required
- Advising on the application of Australia’s thin capitalisation and controlled foreign company (CFC) rules
- Advising on the application of Australia’s MAAL and DPT laws
- Advising on the BEPS Pillar 1 and Pillar 2 measures
- Interest, dividend and royalty withholding tax and the existence and attribution of profits to permanent establishments, including by reference to Australia’s tax treaties and the MLI
- Hybrid mismatches, including with assistance from our global colleagues
- Australia’s international and multinational tax reporting obligations
- Australia’s foreign resident capital gains regimes
- Audit defence, negotiation and litigation services, including in relation to mutual agreement procedures (MAPs) and arbitration under Australia’s double tax agreements and the MLI
- Advising on transfer pricing laws, planning and preparing effective transfer pricing strategies and documentation
- Advising on FATCA and CRS characterisation and compliance issues, including gap assessments and assistance with implementation
