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Expertise

Stephen Jones is a special counsel in Holding Redich’s Tax Controversy team. He specialises in providing taxation advice and tax litigation services. 

Stephen has acted in numerous cases in the Administrative Appeals Tribunal (AAT) and in the Federal Court including Citigroup (2011); TT Lines Company (2009); Gloxinia Investments (2009); Foxtel (2000); White Industries Australia Ltd (2003); Hornsby Shire Counsel (2008) and in the high profile Chevron tax appeals to the Federal Court and Full Federal Court (2015 and 2017). 

The main focus of Stephen’s practice over the last 35 years has been in dispute resolution and taxation advice, representing a variety of clients including multi-national corporate groups, high wealth individuals and domestic companies in ATO reviews, audits and disputes. Stephen also worked in a Big 4 accounting firm’s transfer pricing practice for a number of years on a full range of transfer pricing assignments including preparing documentation.

Experience

Corporate Income Tax, including Transfer Pricing

Stephen was instructing solicitor for the Commissioner of Taxation in the Chevron proceedings in the Federal Court and Full Federal Court which examined for the first time, how Australia’s transfer pricing rules applied to intra-group debt. Robertson J upheld the Commissioner’s assessments against Chevron and the Full Federal Court dismissed Chevron’s appeal. Chevron has filed an application for Special Leave to Appeal to the High Court.

Stephen was also a member of one of the big four accounting firm’s transfer pricing practices for a number of years and has represented a number of Australia’s largest multi-national corporations in transfer pricing disputes before the Federal Court. 

GST

Stephen has provided specialist GST advice since its inception, including acting as instructing solicitor in a number of disputes in the AAT and the Federal Court, including Gloxinia, TT Lines and Hornsby Shire Council. 

Private Client and Tax Compliance Services 

Stephen has acted for a number of high wealth individuals in audit disputes with the ATO on a range of issues including capital gains tax disputes, residency issues and restructuring transactions.

Tax Controversy

Stephen has devoted approximately two thirds of his extensive tax career to tax controversy, namely, disputes with the ATO arising out of its audit activity and in litigation before the AAT and the Federal Court of Australia.

Stephen has been the instructing solicitor in many cases before the Courts, including disputes involving the application Part IVA (FCT v Citigroup), section 39B applications (White Industries; Diahatsu Australia); GST disputes (Gloxinia, Hornsby Council, Petroulias); and a multitude of Part IVC proceedings involving the general income and deductions provisions.