Throughout his career, Paul has been proud to help his clients create value through innovation and commercially-based critical thinking and he is passionate about bringing new opportunities.

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Managing tax detail and compliance can be overwhelming, especially for small and medium-sized and even larger private businesses. From cloud migration to strategice planning, international business to tax and accounting compliance, we offer comprehensive tax services that help you identify and manage potential tax risks before they become a problem, maximise tax opportunities and minimise exposure, take realistic tax positions, and ensure compliance with all ATO requirements.

This way, you can focus on what matters most to you: growing your business.

Our extensive involvement in the industry and deep understanding of legislative and administrative reforms means we are actively involved and up-to-date on all current tax issues that impact businesses. Our knowledgeable teams are dedicated to ensuring that your business is fully compliant with tax regulations and optimized for the best possible tax outcomes.

We believe in providing a personal touch, so our senior engagement leaders take the time to keep you informed and answer any questions you may have. Our goal is to provide you with peace of mind, knowing that your tax affairs are being managed by experienced professionals that are an extension of your team.

The range of our services to private and unlisted businesses is extensive and includes: 

• accounting and taxation compliance
• business advisory
• business and financial structures
• corporate governance
• international business advisory
• outsourced accounting solutions
• performance improvement
• strategic planning
• succession planning.

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Navigating the detail of tax can be a daunting task for businesses and finance teams, particularly for companies with complex transactions, structures and workforces. We’ll help you identify and manage tax risks, maximise opportunities and minimise exposure, take realistic tax positions and ensure compliance with all ATO requirements. 

We have a highly skilled specialist tax teams working with multinational corporations and Australian subsidiaries of overseas companies, as well as Australian and Asia Pacific firms of all sizes.  

Our significant involvement in industry and a high level of involvement in reforms, both legislative and administrative, means we are actively involved and across all current tax issues that impact business.  

We are closely involved in consultative processes, making submissions to Treasury and/or the ATO and have extensive experience managing successful ATO reviews including Combined Assurance Reviews (CARs), Streamlined Assurance Reviews (STARs) and ATO top 20 and top 100 reviews.  

Our team can provide end-to-end solutions across: 

• corporate & International tax advisory 
• Country by Country reporting 
• employment taxes (PAYG, FBT, superannuation and payroll) 
• expatriate taxes 
• FATCA / CRS 
• fuel tax credits 
• fund tax advisory 
• Government grant assistance 
• global workforce mobility services 
• GST and indirect taxes 
• tax due diligence 
• transfer pricing 
• tax structuring 
• tax effect accounting  
• tax governance implementation and review 
• tax controversy, dispute, review and audits 
• tax compliance automation 
• research and development tax incentive 
• remuneration and benefits (share schemes) 
• State taxes (Stamp Duty, Land Tax, GAIC).

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Stephen has acted for a diverse range of clients including individuals, large private groups, government entities and public groups across the funds management, property, manufacturing and higher education sectors. He is a sought after presenter and is a regular speaker at property and higher education seminars on relevant tax issues impacting these sectors.

Stephen’s experience includes:

• Providing strategic advice for tax due diligence on Australian and international property acquisitions
• Advising on European real estate acquisitions valued at over A$2Billion
• Delivering tax compliance for foreign pension funds that have invested in $750m+ real estate in Australia
• Providing tax structuring advice for foreign multinationals investing in Australia, including in relation to income tax, withholding taxes, MIT regime, indirect taxes and employment taxes. The advice covers optimal profit repatriation and exit strategies
• Advising in relation to tax structuring for clients looking to invest in the US, UK, Germany, Spain, Italy, Greece, Singapore, Hong Kong and India
• Assisting clients in relation to complex tax consolidation, CGT, and tax loss recoupment issues, including issues arising on the sale or restructure of businesses and ensuring that appropriate roll-overs are utilised
• Successfully obtaining refunds of withholding tax for clients which have been incorrectly deducted by foreign tax authorities
• Undertaking GST reviews to maximise reduced input tax credit claims
• Performing the role of Tax Technical Advisor for Thomson Reuters’ One Source FBT software.

Stephen is a Partner of SW Audit and a Director of SW Accountants & Advisors Pty Ltd.

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She has strong technical and practical skills advising and assisting clients across a range of industries, but with particular emphasis on funds management and property. Abi’s clients include a number of ASX listed and wholesale property funds, equity funds, corporate entities and large complex private groups.

Abi has been actively involved in submissions to the ATO and the State Revenue Office on numerous land tax, stamp duty and Division 7A issues. She also advises a number of other accounting firms in a specialist capacity on issues affecting their clients.

Abi’s experience includes:

• Advising Funds on the appropriate structure to achieve optimal tax outcomes for investors including consideration of income tax, withholding tax and AMIT regime.
• Providing strategic tax advice for foreign multinationals looking to acquire businesses and properties in Australia.
• Providing income tax, GST and stamp duty advice on M&A transactions.
• Advising large private groups on various complex tax issues such as Division 7A, section 100A, income distributions, tax loss recoupment and management of tax audits.

In addition to her technical skills, Abi has outstanding client management and communication skills.

Abi is a Partner of SW Audit and a Director of SW Accountants & Advisors Pty Ltd.

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Here are some of the key points you should be aware of:

• On first adoption, historical tax positions may need to be evaluated. At the very least, the income years open for amendment may need to be considered.
• The new requirements apply to income taxes only. They do not apply to indirect taxes, for example Goods and Services Tax or State Taxes such as stamp duties and payroll tax. Neither do they apply to employment related obligations such as employer superannuation contributions and work cover. Penalties and interests are only captured if they are accounted for as income tax expense under your accounting policies.
• The requirements are set out in AASB Interpretation 23 (“INT 23”) which entails a three step process as depicted below:

• Having a reasonably arguable position may not mean that the Taxation Authority will accept the tax treatment. You may need to quantify the probability that the Taxation Authority will accept or reject your position.

• You should consider having a conversation internally and with your auditors early to prepare for the adoption of INT 23. The questions to consider include:

  • Who determines the probability of acceptance/rejection by the Taxation Authority of the tax treatment (accept/reject probability)? Is it the finance team, the tax team or your advisors?

  • How do you deal with differences in probability assessments? Who has the final say?

  • How do we make the assessment more objective?

  • Can we apply an algorithm or formula based approach?

  • What are the relevant authorities to be considered in making the assessment?

  • What is the level of documentation expected by your auditors?

Our Corporate and International tax team has penned a detailed article on the new requirements and presented on this topic at our 2019 Complete Tax Solutions (CTS) Conference.  The article proposes a methodology to quantify the accept or reject probability which is directed towards reducing the subjectivity of the analysis.

If you would like a copy of the slide deck and article, please contact marketing@sw-au.com

Get in touch

Our experts can assist with further information.

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