Australia-New Zealand Bilateral IFA Branch Conference 2023

Australia-New Zealand Bilateral IFA Branch Conference 2023


Thursday, 10 August

Time Topic Presenter(s)

8:50am – 9:00am

Conference opening

Niv Tadmore (Jones Day, Australia), Brendan Brown (Mayne Wetherell, New Zealand)

9:00am – 10:00am
Tax treaty policy in Australia and New Zealand

Richard Vann (University of Sydney), Ronita Ram (Australian Treasury), Carmel Peters (Inland Revenue (Policy and Regulatory Stewardship)).

Chaired by Emma Grigg (Inland Revenue (Policy and Regulatory Stewardship)).

10:00am – 10:50am
Approaches to treaty interpretation

Hon Jennifer Davies SC.

Chaired by Miranda Stewart (University of Melbourne).

10.50am – 11:20am

Morning tea

11:20am – 12:10pm
Practical and interpretive tax treaty issues

David Watkins (Deloitte, Australia), Brendan Brown (Mayne Wetherell, New Zealand).

Chaired by Craig Elliffe (University of Auckland).

12:10pm - 1:00pm

Royalties, diverted profits tax and the Pepsi case

Fiona Dillon (Chief Tax Counsel, Australian Tax Office) and additional panellists TBC.

Chaired by Bruce Bernacchi (Dentons, New Zealand).

1:00pm – 1:50pm


1:50pm – 2:50pm
Approaches to limiting interest expense deductions

Chloe Burnett SC, Rhys Manley (Assistant Commissioner, Policy Analysis & Legislation, Australian Tax Office), Kim Michael (KPMG, New Zealand).

Chaired by Anna Tootill (Powerco Limited, New Zealand).

2:50pm – 3:50pm
Taxation of trusts in a trans-Tasman context

Mark Brabazon SC, Fiona Dillon (Chief Tax Counsel, Australian Tax Office), Ben Walker (Deloitte, New Zealand).

Chaired by Paul Sokolowski (Arnold Bloch Leibler, Australia).

3.50pm – 4.15pm

Afternoon tea

4.15pm – 5.30pm
Pillar One, Pillar Two and DSTs

Michael Barbour (Group Head of Tax, Westpac), Casey Plunket (Inland Revenue Policy and Regulatory Stewardship), Kathryn Davy (Australian Treasury), Dean Madsen (EY, New Zealand).

Chaired by Thomas Ickeringill (Allens, Australia).


Drinks and Dinner – The Grille by Eichardt's

Friday, 11 August

Time Topic Presenter(s)
9.00am – 9:45am
The use of fiscal instruments to achieve environmental policy objectives

Ian Parry (Principal Environmental Fiscal Policy Expert, IMF).

Chaired by Chris Cunniffe (Tax Management New Zealand).

9:45am – 10:30am
Environmental tax developments in Australia, New Zealand and the US

Ian Parry, Stephen Bond (New Zealand Treasury), Celeste Black (University of Sydney), Roberta Mann (University of Oregon).

Chaired by Robyn Walker (Deloitte, New Zealand).

10.30am – 11.00am

Morning tea

11.00am – 12.15pm
Tax issues affecting infrastructure investment

Scott McCutcheon (Head of Tax, Infratil), Winnie Kong (Managing Director, Tax (Infrastructure), Brookfield Asset Management), Richard Lambkin (Deloitte, Australia), Sandy Lau (PwC, New Zealand)

12.15pm – 1:30pm
Tax issues affecting transactions with shareholders: share buybacks and other capital reductions, franking, and the hybrid rules

Toby Eggleston (Herbert Smith Freehills, Australia), Paul Korganow (Assistant Commissioner, Policy Analysis & Legislation, Australian Tax Office), Damon Green (Head of Tax, Bank of New Zealand), Sam Lo Ricco (Nuwara, Australia), Fiona Wellgreen (Senior Tax Counsel, Inland Revenue).

Chaired by Clint Harding (Arnold Bloch Leibler, Australia).


Conference close

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