Tax is a highly technical area driven by ever changing and increasingly complex legislation. But for each of us individually and in a business sense, tax is about money. Pitcher Partners has technical skills equal to the larger firms but what we do with this experience is different. We get so close to our clients, we see their businesses as our businesses, so we treat the tax paid as if it was money coming out of our pockets. We interpret the technicalities to give a practical outcome.

Our Tax Consulting division provides the following services:

• Corporate Tax services
• Corporate compliance services
• International Tax services
• Indirect Taxes
• Specialist Tax services

The following Tax Consulting services have been identified specifically for our CPN members:

We can act as agent for your client in negotiating practical settlements with the ATO on disputes and facilitate discussions with the ATO for a timely resolution of such disputes. Such services can vary from discussions and meetings with the ATO to preparation and submission of Position Papers. We can also liaise with legal advisors in relation to any judicial proceedings. We can also attend to preparation and lodgement of objections against assessments and amended assessments.

A significant proportion of our advice covers Capital Gains Tax ("CGT") matters. Advice can cover a variety of areas including structuring for a proposed acquisition, determining the level of CGT arising from a disposal, accessing the CGT small business concessions, and accessing various other capital gains tax rollovers and concessions.

We can assist with advising on appropriate strategies to ensure Division 7A does not adversely apply to your clients. This includes assistance with preparation of loan agreements, calculating minimum yearly repayments, devising tax affective strategies to reduce Division 7A loans, effective debt rationalisations and the application of the old and new Section 109UB in relation to trusts with unpaid distributions to companies.

An increasingly popular service is for us to be able to provide a "health check" covering a variety of scopes. Our reviews can be general or specific depending upon your client's requirements and can cover a variety of areas given our broad range of expertise within our practice.

Preparation for tax effective disposals and acquisitions are key value added services. We understand the commercial drivers behind an acquisition or disposal and therefore are able to provide practical solutions noting the impact of a transaction on the other party. We also liaise with lawyers in relation to review of the transaction documentation.

We are able to advise your clients on whether, how and when they should enter the tax consolidations regime for the wholly owned corporate groups. We can provide a report on the broad issues or provide comprehensive advice on all relevant aspects including the impact of future activities and plans.

Your clients may be seeking to rationalise their structure or facilitate the introduction of new equity participants or key employees. There may be other commercial drivers behind altering an existing business structure. We can provide practical advice on such restructuring with the view to minimising taxation liabilities whilst providing for a flexible structure for the future. The increase in variety of CGT, rollovers and concessions can provide many opportunities for your clients in this regard.

An increasingly popular service we are providing is a review of our clients' estate planning needs. This includes a review of existing structures, review of Wills, life cover, superannuation arrangements, and asset protection objectives. The key challenge for our advice is to deal with the usual tension between desired estate planning outcomes and desired taxation outcomes.

Family businesses and larger business with potential management buy-outs utilise our services in providing commercial and viable tax effective advice on succession plans for such businesses. This provides a clear vision for all parties involved and enables a smooth transition to occur from one generation to another taking into account funding arrangements, taxation outcomes and agreed changes of control.

We prepare ATO product rulings for various primary production managed investment schemes and also ATO class rulings for arrangements involving many parties (example, public company share buy-backs and returns of capital, winding up of industry redundancy funds). Importantly, this involves extensive negotiation with the ATO in seeking the desired ruling outcome.

Often there is a need to obtain certainty on the taxation outcome of a transaction. We can assist by seeking an ATO private ruling which involves us preparing and lodging the application including relevant research and liaising with the ATO to seek the desired ruling outcome.

We have three full time employment tax advisors who deal with the variety of areas for both large and small organisations. This can relate to issues for employers and employees alike covering all relevant employment taxes. Relevant examples include salary packaging, ex-patriot and in-patriot employment arrangements, employee relocations, payroll tax grouping and classifications. This can involve negotiations with the relevant State Revenue Offices.

We have two full time GST advisors. Their services can involve advising on single transactions, prudential reviews/health checks, liaising with the ATO on audit activity and assisting in relation to mergers and acquisitions activities.

In order to utilise time efficiently, we strongly encourage you to provide as much detail as possible onto this tax query sheet.

CPN Tax Query Sheet (Melbourne)