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Tax Controversy / Disputes

Confident advocacy in tax controversy matters

Tax authorities in New Zealand and internationally continue to face sustained pressure to increase revenue. Russell McVeagh’s Tax Controversy and Disputes team helps clients manage risk, protect their position, and achieve commercial outcomes throughout adversarial and often complex tax investigations and disputes.

Our approach

We advise clients at every stage of a tax dispute or investigation, from early engagement with Inland Revenue through to settlement and litigation, in relation to all manner of tax issues. Our work includes:

  • Assisting with information requests and audits
  • Guiding clients through Inland Revenue investigations
  • Advocacy through the statutory disputes process, ensuring arguments advanced at early stages do not prejudice subsequent court-based challenges
  • Advising on cross-border and multi-jurisdictional disputes, including transfer pricing and support through treaty-based pathways
  • Negotiating settlements and alternative resolution pathways
  • Representing clients in tax litigation at all levels of the New Zealand courts

While many disputes are resolved without litigation, we are highly experienced in taking complex, high-value tax disputes through to trial and appeal where required.

One team, integrated expertise

We work as one integrated team, drawing on the combined strength of our market-leading tax and dispute resolution practices. As a full-service law firm, we are able to coordinate expertise across an entire dispute, drawing on legal subject-matter specialists as required.

Where matters have an international dimension, we work seamlessly with leading offshore advisers to coordinate strategy and manage multi-jurisdictional investigations and disputes.

Experience

We have a long history of advising on complex tax disputes across all major taxes and sectors, for both New Zealand and international clients. Our experience includes acting for:

  • the successful voluntary administrators in proceedings declaring they were not personally liable for GST on supplies by the company in voluntary administration (Meltzer and Lamacraft v Commissioner of Inland Revenue [2026] NZHC 979) (see our update)
  • the receivers of an offshore oil field operation, in relation to tax issues regarding the Crown's entitlement to set off tax refunds against its claims against insolvent companies (Re Tamarind Taranaki Ltd (in rec & liq)) (heard in the High Court in February 2026, judgment expected 2026)
  • Trustpower in the High Court, Court of Appeal and Supreme Court on its dispute concerning the deductibility of feasibility expenditure. (Trustpower Ltd v Commissioner of Inland Revenue [2013] NZHC 2970; [2015] NZCA 253, [2016] NZSC 91)
  • Vector in the High Court and Court of Appeal, successfully defending the income tax treatment of payments it received from a third party for the right to lay and install cables and other equipment (Vector Ltd v Commissioner of Inland Revenue [2014] NZHC 2069, [2016] NZCA 396)
  • Michael Hill Finance in the High Court and Court of Appeal, arguing the Commissioner was bound to adopt consistent tax treatment as between similarly-placed taxpayers (Michael Hill Finance (NZ) Ltd v Commissioner of Inland Revenue [2015] NZHC 3144, [2016] NZCA 276)
  • Provident Insurance in the High Court in relation to the GST treatment of certain credit contract indemnity policies covering loan repayments (Provident Insurance Corporation Ltd v Commissioner of Inland Revenue [2019] NZHC 995)
  • a high-net-wealth individual in relation to his claim for a significant donation tax credit in relation to a donation made to a charity he had founded (settled out of court)
  • multinational clients in relation to transfer pricing disputes, both in domestic proceedings and through assistance with the treaty-based mutual agreement procedure, including:
    • A US-headquartered S&P100 technology company in relation to software sublicence fees paid by its New Zealand subsidiary to an Irish parent company
    • A US-headquartered S&P500 automobile manufacturer in relation to the prices paid for vehicles and parts by its New Zealand subsidiary to other group members
    • A NZ-headquartered multinational exporter in relation to a transfer pricing challenge by the Indonesian tax authority
  • Several banks in relation to various iterations of structured finance tax litigation arising from the early 2000s
  • Simunovich Fisheries in the High Court and Court of Appeal in relation to its substantive and procedural challenges to GST assessments (Simunovich Fisheries Ltd v Commissioner of Inland Revenue (2002) 20 NZTC 17,456)
  • Renouf Corporation in the High Court in relation to its substantive challenge to tax assessments and pre-trial evidentiary issues (Renouf Corporation Ltd v Commissioner of Inland Revenue (1998) 18 NZTC 13,627)
  • Port Chalmers Waterfront Workers Union in the High Court on its challenge to income tax assessments in relation to certain equity payments (Port Chalmers Waterfront Workers Union v Commissioner of Inland Revenue (1995) 17 NZTC 12,059)