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John Boyagi

Partner

,

Sydney

John is an experienced tax controversy and dispute resolution lawyer with deep expertise in managing complex, high value Australian tax disputes for multinational corporations, listed entities and ultra high net worth individuals.

John advises clients across the full lifecycle of tax disputes, from risk assessment and audit strategy through to objections, negotiations with the regulators and litigation before the Courts.

John is recognised for his expertise in complex matters involving transfer pricing, anti‑avoidance provisions, cross‑border structuring, and the characterisation of income and payments. His experience spans a wide range of industries, including mining, manufacturing, infrastructure, real estate, automotive and professional sport, and he regularly acts in disputes with significant financial and reputational implications for clients

  • +61 2 8289 5890

Expertise

John’s expertise includes:

  • Tax controversy and litigation, including ATO audits, reviews, objections, settlement negotiations and proceedings before the Courts
  • Transfer pricing disputes and audits, advising on related‑party financing, intellectual property arrangements and cross‑border operating models for global groups
  • Anti‑avoidance and integrity provisions, including Part IVA matters involving restructuring, IP migration, profit allocation and complex financing arrangements
  • Cross‑border tax issues, including disputes arising from inbound and outbound investment structures, multinational supply chains and international tax characterisation issues
  • Private wealth and family groups, advising ultra‑high‑net‑worth individuals on income tax, SMSF, land tax and integrity‑based audits and disputes
  • Indirect tax and state tax disputes, including land tax matters, particularly those involving primary production and exemption issues.

Recent Matters

  • Acted for a global mining multinational in multiple transfer pricing audits and disputes involving complex cross‑border transactions and financing arrangements, including negotiations with the ATO on settlement strategy
  • Represented an ultra‑high‑net‑worth family group in a significant Part IVA and SMSF audit and dispute, advising on audit strategy, submissions and dispute resolution pathways
  • Advised a global machinery and manufacturing group on a cross‑border financing transfer pricing audit, including issues relating to interest deductibility and pricing of related‑party debt
  • Acted in NSW land tax disputes concerning the availability of primary production exemptions for property holdings, including engagement with state revenue authorities
  • Represented clients in disputes under Division 855 relating to the sale of shares in entities holding Australian infrastructure assets and the taxation of capital gains
  • Advised multinational clients on Part IVA and transfer pricing disputes arising from the transfer of Australian‑based intellectual property to offshore related entities
  • Acted for global and domestic clients in income tax disputes involving the utilisation of tax losses, including disputes with significant quantum exposure
  • Advised sporting organisations and major participants in disputes concerning the characterisation of royalty and income payments, including payments for live‑streamed sporting vision and player image rights.