Australia
Andy Bubb
PartnerAbout
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
Professional QualificationsBarrister and Solicitor of the Supreme Court of VictoriaSolicitor of the High Court of Australia
EXPERIENCE
- Advising on an ATO audit of a US MNE in the technology sector focussing on royalty withholding tax and permanent establishment issues.
- Advising various multinationals (including several Fortune 500 companies) in relation to the royalty withholding tax and diverted profits tax implications of the decision by the High Court of
- Australia in Commissioner of Taxation v PepsiCo, Inc [2025] HCA 30.
- Advising on an ATO audit of a US MNE in the retail sector focussing on treaty shopping and transfer pricing.*
- Advising on an ATO audit of an Australian infrastructure asset owned by foreign pension and sovereign wealth funds focussing on trust taxation, general anti-avoidance rule and transfer pricing issues.*
- Advising on an ATO audit of a global energy company focussing on transfer pricing, the general anti-avoidance rule, the multinational anti-avoidance rule and the diverted profits tax for two global restructures.*
- Advising on an ATO audit of a US MNE automotive manufacturer focussing on capital gains tax / land-rich, general anti-avoidance rule and transfer pricing issues.*
- Advising on an ATO audit of an ASX-listed entertainment client focussing on its UK business disposal, CFC rules and the general anti-avoidance rule.*
- Advising on an ATO and state revenue office audits of a technology / gig economy client focussing on whether its workforce were employees or contractors.*
*Experience gained from a previous company
Languages
- English
Education
- Chartered Tax Adviser, The Tax Institute, 2015
- Bachelor of Laws (Hons), Monash University, 2011
- Bachelor of Commerce, Monash University, 2011
Publications and media
- Co-author, "New Australian Tax Reporting Law Opens Door to Fines, Scrutiny", Bloomberg Tax, 7 February 2025.
- Co-author, "New Test, New Doubts on Royalty Withholding Tax and Diverted Profits Tax from Pepsi Appeal", Bloomberg Tax, 27 June 2024.
- Co-author, "Australia's Budget Puts Many Issues on Multinationals' Radar", Bloomberg Tax, 31 May 2024.
- Co-author, "IRS' and ATO's latest views on hot tax issues for multinationals", Bloomberg Tax, 22 March 2023.
Seminars
Presentations
- Co-presenter, "PepsiCo and Taxing IP: Where to from here?", Corporate Tax Association National Convention, 15 October 2024.
- Co-presenter, "Navigating Intangible Assets from a tax and TP perspective", TP Minds Sydney, 2024.
- Co-presenter, "The Modern ATO Audit: Everything, Everywhere All At Once", Corporate Tax Association National Convention, 9 October 2023.
- Co-presenter, "Managing Transfer Pricing Controversy and Disputes", TP Minds Sydney, 2022.
Media
- TV appearances as expert commentator on the Pepsi decision, Business Weekend with Ross Greenwood, Sky News, 2023 and 2024.
- Quoted, "Pepsi beats ATO on appeal over royalty taxes", Australian Financial Review, 26 June 2024.