Helping clients navigate complex tax issues, risks and challenges across the entire tax continuum

Tax controversy

The MinterEllison Tax Controversy Practice is the largest and only dedicated controversy practice in Australia focussed on the management of any engagement with the ATO including risk review, audit or dispute. We provide large corporations and multinational companies assistance with managing large ATO risk reviews, audits, and to proactively engage with the ATO to achieve successful outcomes with their APAs (advance pricing arrangements) or other issues that require tax certainty.

As an adviser to the ATO and with team members previously occupying senior ATO positions, clients value our relevant perspective and our team is uniquely placed to apply their insights and perspectives to management of the ATO relationship. This includes the applied knowledge of ATO processes of information gathering, decision making and the manner in which tax risk hypotheses are formed and actioned.


Knowledge and expertise

Through our specialist skills, understanding of risk governance and deep sector knowledge, we offer clients insights to identify potential tax risks and achieve effective outcomes.

Navigating complex tax controversy challenges with expertise

Businesses with complex Tax Controversy challenges need access to expertise in all areas of tax to achieve an optimal outcome with the ATO. Our multi-disciplinary Tax Controversy team is fully equipped to support any interaction that involves consideration of a tax position - be it transfer pricing, diverted profits tax, application of anti-avoidance provisions or any other tax provision. Endowed with cutting edge capability and experience, and a track-record for achieving best outcomes throughout the ATO engagement. As a result of our team having conducted the most complex tax litigation, on behalf of and against the ATO, we understand the importance of an evidence based approach to support tax positions including during early engagement with ATO.


Meet the team helping clients navigate complex tax issues, risks and challenges across the entire continuum.