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Andy Bubb

Partner
Melbourne
About

Andy focuses on resolving complex tax disputes, particularly for large multinationals. He has market-leading expertise in contentious international tax and transfer pricing matters, particularly the application of Australia's anti-avoidance rules, transfer pricing and tax treaties. He has wide experience in ATO dispute processes, having represented clients in various ATO processes and successfully negotiated settlements.

Andy has been recognised by various industry bodies, including winning the International Tax Review's award for APAC Tax Litigation Rising Star in 2025 and being listed by Doyle's Guide as a Recommended Tax Lawyer.

Areas of FocusTaxEnergy and Natural ResourcesTechnologyInfrastructure, Construction and TransportConsumer Goods, Food and Retail

EXPERIENCE

  • Advising one of the world's largest companies on the ATO's investigation of a treaty shopping issue.
  • Advising a technology company on the ATO's investigation of royalty withholding tax and permanent establishment issues.
  • Advising various foreign owned consumer brands on the implications of the High Court's decision in Pepsi about royalty withholding tax and diverted profits tax.
  • Advising an infrastructure client on a complex ATO audit of an Australian infrastructure asset owned by foreign pension and sovereign wealth funds, addressing GAAR and transfer pricing issues.*
  • Advising a gig-economy client on parallel investigations by the ATO and state revenue offices about whether the client's workforce were employees or contractors for tax purposes.*
  • Advising a client in the ENR sector on a multifaceted ATO audit relating to the income tax and transfer pricing implications of two global restructures.*
  • Advising an investment fund client on an ATO audit of relating to whether capital gains tax (CGT) applied to a share sale, which depended on whether the shares were taxable
  • Australian real property (TARP).*
  • Advising an automotive client on a multinational automotive client's restructure, including the general anti-avoidance rule (GAAR) and income tax issues.*
*Experience gained from a previous employer
Languages
  • English
Education
  • Chartered Tax Adviser, The Tax Institute, 2015
  • Chartered Accountant, Chartered Accountants Australia and New Zealand, 2015
  • Graduate Diploma of Legal Practice, The Australian National University, 2013
  • Bachelor of Laws (Hons), Monash University, 2011
  • Bachelor of Commerce, Monash University, 2011

Memberships and Affiliations

Law Institute of Victoria

Connect

Phone

+61 3 9274 5054
(Work, Melbourne)
+61 431 353 325
(Mobile)
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