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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
Professional QualificationsBarrister and Solicitor of the Supreme Court of VictoriaSolicitor of the High Court of Australia

EXPERIENCE

  • Advising US MNEs in the technology sector on an ATO audit focussing on royalty withholding tax (RWT) and permanent establishment (PE) issues.
  • Advising a European MNE in the telco sector on an ATO audit focussing on RWT and transfer pricing (TP) issues, including MAP and FTC possibilities.
  • Advising MNEs (including Fortune 500 companies) in relation to the RWT and diverted profits tax (DPT) implications of the decision by the High Court of Australia in Commissioner of Taxation v PepsiCo, Inc [2025] HCA 30.
  • Advising a US MNE in the retail sector on an ATO audit focussing on treaty shopping and TP.*
  • Advising pension and sovereign wealth funds on an ATO audit of their Australian infrastructure asset investment, focussing on trust taxation, general anti-avoidance rule (GAAR) and TP issues.*
  • Advising a global energy company on an ATO audit focussing on TP, the GAAR, the multinational anti-avoidance rule (MAAL) and the DPT for two global restructures.*
  • Advising on a technology / gig economy client on parallel audits by the ATO and State Revenue Offices about whether its workforce were employees or contractors.*
*Experience gained from a previous company
Languages
  • English
Education
  • Chartered Tax Adviser, The Tax Institute
  • Bachelor of Laws (Hons), Monash University
  • Bachelor of Commerce, Monash University
  • Graduate Diploma of Legal Practice, Australian National University

Publications and media

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

 

My latest insights

Podcast

Pepsi v. ATO: What Australia's landmark tax case means for multinationals

27 October 2026 .1 minute read

Publication

ATO finalises software royalty ruling and expands practical compliance guidance

16 September 2026 .6 minute read

Publication

Australia’s Tax Proposals Mean No Capital Gain Without Pain

12 June 2026 .5 minute read

View All

Connect

Phone

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

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