Graham Murray

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Graham is a tax specialist, leading the firm's tax practice with broad experience across a range of industries and transactions.

Graham’s areas of focus include the taxation of corporate restructuring, mergers and acquisitions, cross-border investment arrangements and joint venture structures. He has expertise in the taxation of financing arrangements, in particular securitisation structures and cross-border lending/debt acquisitions.

Graham has engaged with the Inland Revenue Department for various clients in contentious tax disputes and obtaining binding rulings, determinations and indicative views. His other areas of expertise include funds management, including a detailed working knowledge of the portfolio investment entity (PIE) rules, and double tax treaty issues. Graham also advises a diverse range of private clients and new migrants on a range of New Zealand personal tax issues.

Graham is focused on providing sound and practical advice on complex tax issues. He is experienced across a broad range of industries and focuses on understanding his client's business needs and delivering solutions.

Chambers Asia Pacific 2023 ranks Graham as a leading lawyer for tax. In previous editions, Chambers Asia Pacific 2022, Graham was also ranked with clients praising him for being "technically sound, pragmatic, client-focused and a pleasure to deal with." A client says he is a "great communicator" who "thinks outside the box to achieve sensible and pragmatic outcomes for clients." In previous editions, Graham was described as being "very accessible and available to work to tight deadlines" and as an "astute and knowledgeable" tax lawyer who adopts a "sensible and constructive approach."

The Legal 500 Asia Pacific 2024 ranks Graham as a leading lawyer in tax. In previous editions, clients described him as "brilliant." "He managed to balance being very technically astute with commercial pragmatism. He was always quick to grasp complex technical issues (both UK and NZ) and deliver helpful practical advice."

World Tax 2022 ranks Graham as a "highly regarded tax leader" across transactional tax matters in New Zealand.

Work highlights

Sale of Carter Holt Harvey pulp, paper and packaging business
Advised Rank Group and its subsidiary Carter Holt Harvey on the taxation aspects of the sale of the New Zealand pulp, paper and packaging business to the Oji Holdings Network Corporation and Innovation Network Corporation of Japan for NZ$1.037 billion. In particular, advising on pre-sale restructuring, transaction sequencing and negotiating tax clauses in the sale and purchase documentation.

Acquisition of Transpacific Industries Group
Advised on tax matters on the acquisition of the Transpacific business in a competitive bid process, including conducting purchaser tax due diligence, advising on ownership and debt structuring matters, negotiating tax clauses in the sale and purchase agreement and reviewing tax assumptions in a purchaser's financial model.

Tax warranty and indemnity insurance
Advising insurers offering tax warranty and indemnity insurance on New Zealand share sale transactions. This work typically involves assessing the quality of purchaser tax due diligence, reviewing tax warranty and indemnity provisions to assess conformity to market practice and drafting tax-related policy exclusions for excluded risks.

Inland Revenue Department disputes
Advising corporate clients with on-going disputes with the Inland Revenue Department concerning capital and revenue boundary issues and the taxation of hybrid financing arrangements, in addition to advising clients on tax pooling in the disputes context.

Britomart precinct development
Advising Cooper and Company on the tax issues applicable to the development and ongoing operation of the Britomart precinct in Auckland. Graham's involvement spans tax and GST advice on all aspects of the project including construction and finance, general corporate income tax advice and advising on tax disputes.

Q Card securitisation
Advising Fisher & Paykel Finance on the taxation aspects of its Q Card securitisation trust, including reviewing the securitisation documents from a tax neutrality perspective and advising on the tax treatment of the trust.

Motor Trade Finances securitisation
Advising Motor Trade Finances the securitisation trust arrangements for New Zealand motor vehicle receivables.

New Zealand Guardian Trust trustee advice
Advising New Zealand Guardian Trust on its participation as trustee of securitisation trusts, including the tax consequences of participation and tax neutrality reviews of the transaction documentation.

Funds management
Advising AMP Capital on the establishment of new portfolio investment entity (PIE) funds and the taxation of existing PIE funds. Advising Craigs Investment Partners on various tax matters relating to superannuation schemes, KiwiSaver schemes and PIE funds and transfers of foreign super entitlements to New Zealand schemes.

New migrants
Advising new migrants and non-residents on New Zealand tax residence issues, the operation of the transitional residents exemption, treaty protection matters and New Zealand property ownership structures.

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Work highlights

Insights by Graham