Craig Silverwood
Partner*, Melbourne
As an economist with more than 15 years of dedicated consulting and ATO experience, I provide clients with specialist International Tax and Transfer Pricing advice.

I solve complex multinational tax issues and cross-border operational challenges by combining economic principles, business acumen and data analytics. I also specialise in cross border transactions, structuring deals, tax risk management and in controversy.

Former clients include prominent Australian and foreign owned multinational enterprises and Australian entrepreneurs across a range of sectors including energy and resources, private equity, infrastructure, fast moving consumer goods, automotive, food and beverage, technology, media, retail, e-commerce and financial services.

Career highlights

  • Experienced senior team member of an International Tax and Transfer Pricing team at a Big 4 accounting firm
  • Several years' experience as an ATO economist, focused on international tax matters and tax data analytics
  • Negotiated over 20 Advance Pricing Arrangements, providing clients with certainty on complex international related party dealings and collateral tax issues
  • Managed and resolved several complex transfer pricing controversy matters including ATO reviews, audits, settlements and obtaining double tax relief under the Mutual Agreement Procedure article in Australia's tax treaties
  • Successfully defended a client's Multinational Anti-Avoidance Law position that was subjected to a detailed ATO review.
  • Designed and implemented an intellectual property framework for a large multinational consumer products business
  • Conducted analytical assessments of multinational business value chains, including the interpretation of Country by Country Reporting tax data
  • Advised on the international tax and transfer pricing structuring aspects of a number of significant Corporate M&A and Private Equity transactions, both pre and post-acquisition
  • Managed Foreign Investment Review Board tax conditions relating to regulatory review of shareholder debt arrangements and post-merger supply chain integrations
  • Provided in-house transfer Price thought leadership and training sessions to prominent multinational groups
  • Acted as guest lecturer at the University of Melbourne for students studying "Transfer Pricing Practice and Problems".

*not an Australian legal practitioner