Chris Peadon

Practice Areas

Chris maintains a busy tax advisory and disputes practice.

He regularly advises corporate clients upon the tax implications of domestic and cross-border transactions, as well as advising high net worth (HNW) groups on restructures and succession planning. His expertise in both Commonwealth income tax and state taxes (including stamp duty and landholder duty) enables him to provide comprehensive advice on all tax consequences.

His advice is informed by his extensive experience managing disputes for both taxpayers and the Commissioner concerning taxation of gains by non-residents (including “TARP” and Tax Treaty issues), transfer pricing, capital gains, landholder (“land rich”) duty, and the anti-avoidance provisions (Part IVA including “dividend stripping”).

Chris has appeared in many of the leading tax cases over the past decade. Recent cases include appearances for taxpayers in the Full Federal Court in the Singtel transfer pricing case arising from its $14.2 billion acquisition of mobile telecommunications company Optus, and for the Bechtel multinational engineering group on the deductibility of “Fly-in Fly-out” employees’ travel costs for major infrastructure projects. Other clients for whom he has acted include News Corporation entities, John Holland, Snowy Hydro, Aurizon (formerly National Rail), the liquidators of both The Bell Group and Lehman Brothers, and several large private groups and high net worth individuals.

Chris has also been involved in several leading charities cases for The Salvation Army, YWCA, and the RSL.

Chris’ expertise extends to advising taxpayers and financiers on funding arrangements and disputes in relation to various tax offsets including those available for research and development (R&D), film and television production (e.g. “producer offset”) and the recently introduced Digital Games Tax Offset.

Chris’ tax expertise is acknowledged in client survey responses:

- Chris is a “‘very experienced junior’ who combines a hands-on approach with ‘a similar level of experience and expertise to, and a lot of the softer skills of, a QC'” - Chambers Asia Pacific 2022

- Chris commands “respect as one of those barristers ‘who live and breath their profession’” and are comfortable calling him on difficult matters “since he’s done it all” – Chambers Asia Pacific 2021.

In addition to his tax practice, Chris acts in commercial causes, commonly for Lloyd’s Syndicates in financial lines insurance matters. He acted for the D&O underwriters in coverage disputes concerning claims made against the directors of Babcock & Brown following its collapse.

Career

Solicitor, Allens + Linklaters (Australia) (2001-2011)

Barrister, NSW Bar, (2011 to present)

Work Highlights

Acting for:

– News Corporation in its successful claim for A$2.2 billion of foreign exchange deductions resulting in an A$850 million tax refund

– Aurizon Ltd in a successful application for declarations concerning whether a A$4.2 billion shareholder contribution was “share capital”, with favourable tax consequences for shareholders participating in share buy-backs.

– The Bell Group (in liq) in its appeal from a A$260 million assessment following the successful multi-billion claim against its banking syndicate

– Singtel in its ongoing transfer pricing dispute with the Commissioner concerned interest on the A$5.2 billion loan used to partially fund the A$14.2 billion acquisition of Optus in 2002.

– The Commissioner of Taxation in the successful appeal to the 5-member bench of the Full Federal Court concerning the taxation of the significant gain made by the non-resident Resource Capital Fund group on its disposal of its interest in the Talison Lithium mine.