Taxation and Revenue

Our team consists of lawyers with both legal and accounting qualifications as well as postgraduate qualifications to provide excellent technical and commercial advice.

Corporate Tax

The Review of Business Taxation has introduced significant changes to the taxation of corporate entities.

We provide meaningful corporate tax advice to assist you in absorbing the many significant changes to the taxation of corporate entities including consolidations, value shifting, the demerger provisions, scrip for scrip rollover rules and the debt/equity provisions.

Stamp Duty

When undertaking any property or business acquisition or disposal, the implications of stamp duty and other state taxes should not be overlooked.

Middletons’ Taxation and Revenue team works closely with each of the State Revenue Offices to expedite the stamping of documents and to seek opinions to facilitate the smooth flow of transactions.

Our team has also been heavily involved in objecting to assessments to Victorian stamp duty in respect of duty imposed on goodwill associated with combined sale of land / business transactions.

Tax Audits and Disputes

With increased ATO activity in reviewing the affairs of taxpayers, we often represent clients that are in dispute with the ATO. We have successfully resolved disputes in connection with:

• the CGT cost base rules
• the application of the superannuation guarantee rules
• the application of royalty withholding tax and freight tax to time charters
• the issue of directors penalty notices
• the treatment of offshore superannuation schemes.

International Tax

Cross border transactions involve significant issues for both Australian entities seeking to expand overseas and foreign entities seeking entry into Australia.

Middletons has advised both Australian and foreign based entities on inbound and outbound investment transactions, structuring, transfer pricing issues, withholding tax, thin capitalisation, permanent establishment issues and consideration of Double Tax Agreements.

We’ve also advised on Australia’s controlled foreign company, foreign investment fund and transferor trust rules.

Goods and Services Tax

The Goods and Services Tax (GST) has affected clients in every industry group.

Middletons’ Taxation and Revenue team has acted for a range of clients in various industries including the shipping industry and the property sector regarding GST free supplies and international trade, the application of the margin scheme, leases and review opportunities, new residential premises and going concern issues.

We have successfully applied for GST private rulings dealing with partnerships and going concerns.