Edmund Yuan
Lawyer
Justin Lai
Lawyer — Tax
Prudence Birchall
Lawyer
Adrian Fourie
Senior Associate
Molly Tredinnick
Senior Associate
Alyse McDermott
Lawyer
Reilly King
Senior Associate
Naeha Lal
Special Counsel

Annalie Mitchelson

Partner

Annalie has over two decades of experience advising corporate taxpayers with a focus on tax litigation, dispute resolution, and R&D tax disputes. Her experience includes acting in complex tax matters involving transfer pricing, anti-avoidance and R&D disputes, and the detailed collation, analysis and presentation of compelling evidence to drive a successful resolution of disputes.

Annalie assists Australian and multinational clients to develop tax risk management strategies and provides practical and strategic advice to manage risk reviews and audits, from the early stages through to litigation or settlement. During her career, Annalie spent 16 years in multinational professional services firms in tax controversy and spent several years working with the Australian Government Solicitor, litigating on behalf of the Commissioner.

AREAS OF EXPERTISE

Tax; Tax litigation; Dispute resolution; R&D tax disputes; Tax risk management strategies

QUALIFICATIONS
  • Master of Taxation, University of Sydney
  • Bachelor of Laws, University of Technology – Sydney, (First Class Honours)
  • Bachelor of Business, University of Technology – Sydney
  • Admitted to practice in New South Wales and High Court of Australia
SELECTED REPRESENTATIONS
  • 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.

 

*Experience was undertaken at a previous firm