Rimma Miller
Partner, Sydney
With over 20 years' experience in taxation, I help clients navigate reviews, audits, objections and other tax-related disputes. I am an experienced tax litigator, having represented clients in all federal and state jurisdictions. I use insight gain from litigation to assist clients, where appropriate, to resolve their matters without resorting to legal proceedings

My practice is founded on providing objective advice and assessments, and I take a strategic, balanced approach to taxation matters. My clients include major listed and privately held corporations, private clients, as well as the Australian Taxation Office (ATO).

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

Career highlights

  • Assisted in successful resolution of a transfer pricing disputes for clients including a global Life Sciences client and a top listed Energy and Resources client.
  • Assisted in successful resolution of taxation disputes for a global Energy and Resources client.
  • Facilitated a successful out of court resolution of a GST related dispute for a Building and Construction client.
  • Assisted in successful resolution of tax disputes involving an application of anti-avoidance provisions for several ASX listed clients in Financial Services and in Energy and Resources sectors.
  • Assisted several high net worth clients to successfully navigate and resolve their taxation disputes with the ATO.
  • Acted as an instructing solicitor in leading tax litigation in all relevant jurisdictions, including in Federal Court of Australia and High Court of Australia representing the Commissioner of Taxation, including most recent matters of PepsiCo v Commissioner of Taxation, Hilton Resorts v Commissioner of Taxation (decision pending), as well as Mussalli v Commissioner of Taxation, Origin Energy v Commissioner of Taxation, Sibai v Commissioner of Taxation, RCF IV/V v Commissioner of Taxation, Blank v Commissioner of Taxation, Oswal v Commissioner of Taxation and many others.
  • Facilitated a successful resolution of a dispute between an ASX–listed Financial Services company and the ATO related to the consolidated group’s carry-forward losses.
  • Providing ongoing assistance and representation to a large privately held group of companies in relation to GST related disputes with the ATO.
  • Advised and represented several overseas based corporations in relation to the issues arising out of their acquisitions of an interest in an Australian-based resources company and an application of TARP provisions.
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https://www.minterellison.com/people/rimma-miller