Rimma Miller
Partner, Sydney
With more than 15 years' experience in taxation, I help clients navigate audits and other tax-related disputes. I am also an experienced litigator, having represented clients in all federal and state jurisdictions.

My practice is founded on providing objective advice and assessments, and I take a strategic, balanced approach to taxation matters whether I am representing private clients or the Australian Taxation Office (ATO).

I am committed to minimising tax disputes by providing preventive tax risk management and governance solutions. I also work with clients to establish efficient and cost-effective ways to resolve or manage ATO disputes.

Career highlights

  • Advise and represent an ASX Top 100 company in a GST dispute with the ATO.
  • Advise an ASX Top 100 company in relation to transfer pricing audit by the ATO.
  • Advise and represent several clients in Part IVA anti-avoidance matters.
  • Advise and represent clients in several ongoing Federal Court matters dealing with a capital/income characterisation of the expense.
  • Successfully acted as an instructing solicitor in significant Federal Court of Australia and High Court of Australia cases, including recent matters such as Blank v Commissioner of Taxation and Oswal v Commissioner of Taxation.
  • Facilitated a successful resolution of a dispute between the ATO and an ASX–listed company related to the consolidated group’s carry-forward losses.
  • Advised and assisted the resolution of a dispute between an ASX Top 100 company and the ATO involving matters arising out of past restructures and consolidation issues.
  • Advised an overseas based corporation in relation to the proposed acquisition of a partial interest in an Australian-based resources company and a potential application of TARP provisions.
  • Resolved a dispute between a large listed construction company and the ATO, related to a capital gains tax liability.