Annalie Mitchelson

Advised a Japanese conglomerate in an international tax dispute regarding tax treaties and treatment of capital gains.

Acted in court proceedings for a major agricultural producer in a dispute concerning the research and development tax incentive.

Advised a large pharmaceutical company in a transfer pricing dispute with the ATO.

Advised on an ongoing ATO audit of a global acquisition and restructure of a large global chemical group – issues included the tax anti-avoidance rules, tax residency, availability of tax losses, and capital gains tax.

Advised a global mining group on an ATO audit examining issues arising from a global funding restructure, including Part IVA and transfer pricing.

Acted for a US-headquartered multinational client responding to an ATO audit regarding the sale of a global business, issues included valuation, transfer pricing, anti-avoidance, and capital gains tax.

Acted for a multinational telecommunications company in a transfer pricing dispute concerning the arm’s length nature of significant intra-group financing arrangements.

Acted for an Indian technology company in a tax dispute regarding transfer pricing and royalty withholding tax.

Advised a not-for-profit client responding to a Royal Commission enquiry.