Chris Peadon

Practice Areas

Chris’ busy tax advisory practice complements his disputes practice.

His expertise in international tax is marked by his roles in 2024 acting for Singtel in its $830 million transfer pricing dispute (which reached the High Court on special leave), and leading the Commissioner’s Counsel team against two Silks in Newmont’s $320 million foreign resident capital gains dispute.

On the advisory side, recent engagements include advising multinational technology companies on royalties issues in light of the recent Pepsi decision, a multinational on the application of the controlled foreign corporation (or “CFC”) rules to foreign corporate amalgamations, and in respect of various transfer pricing issues.

Chris also advises and acts for taxpayers and the Commissioner on a broad range of domestic tax issues.

He maintains a busy practice acting for HNW groups and individuals, including advising on restructures and inter-generational wealth transfer arrangements.

His expertise in stamp duty is marked by having acted for taxpayers in leading cases on landholder duty including for charities and arrangements attracting the “just and reasonable exemption”.

Chris is also experienced in advising and conducting reviews for taxpayers in respect of specialist tax offsets for R&D, film, television, and digital games.

Chris has been recognised as a leading junior tax counsel in Australia for several years as illustrated by recent 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.

- Chris provides “practical, clear proactive advice” and he has “a good relationship with clients and is able to explain the issues in layman’s language." – Chambers Asia Pacific 2023

Career

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

Barrister, NSW Bar, (2011 to present)

Professional Memberships

Law Council of Australia – Tax Committee

Tax Institute of Australia

Australian Bar Association

NSW Bar Association

Publications

Chris regularly publishes and presents papers on topical issues. A selection of his personal favourites are curated below:

- “Dividend stripping: the life and times of s 177E” (2011) 26(1) Australian Tax Forum 51

- “Practising the Dark Arts in the Age of Enlightenment” (Sept 2016), presented at the NSW Law Society Continuing Education Program

- “Scope for Future Development of Constitutional and Administrative Law Aspects of Tax Appeals”, paper presented to the NSW Bar Association Constitution and Administrative Law Section (February 2014) (postscript: selected because shortly afterwards the key proposition was roundly rejected by the Full Federal Court).

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 interests 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.